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Okay this section is the starting point no.3

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There are a lot of people who do this

3
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like 36% of people about 10% of people

4
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So I am going to show you guys the rate of each

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Beef

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Ready, Wendy?

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Okay.

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Good morning, everyone.

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This is Judge Kaplan.

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And we will be starting our hearings on BlockFi, Inc. and Al.

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And before I hear from Debtors Council, let me just make note.

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I anticipate this morning to be virtually all informational.

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No arguments are scheduled, but it's a good thing that we have a good

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opportunity to allow all parties to update the court and all parties

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that interest on where matters stand.

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And in that regard, I did want to express my appreciation to the debtor

17
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and both the official and ad hoc committees on putting together a

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joint court hearing.

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And I'm going to be giving a brief introduction to the process.

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And both the official and ad hoc committees on putting together a joint

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correspondence to stakeholders trying their best in these trying times

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to update the parties on where matters stand to try to lessen the

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confusion that's out there.

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And I think it was a great first step in that direction.

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Today, those in court will unfortunately not have the benefit of our

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00:02:04,980 --> 00:02:07,980
technology in saying who's on Zoom.

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Our screen is not working in that regard.

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However, we do have Zoom participants, I don't know, approximately 120 or

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so at the moment.

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For those who are on Zoom who want to be heard, please just as always use

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the raise hand function.

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I can certainly see you all.

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And those in court will be able to hear you.

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So at this juncture, let me turn to Debtors Council.

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Ms. Okike.

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00:02:39,980 --> 00:02:41,980
Good morning, Your Honor.

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00:02:41,980 --> 00:02:44,980
Christina Okike of Kirkland & Ellis on behalf of the debtors.

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Your Honor, we wanted to provide just a brief update on the debtors' cash

39
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and the current situation.

40
00:02:51,980 --> 00:02:56,980
So, Your Honor, there have been a lot of reports of BlockFi's potential

41
00:02:56,980 --> 00:02:59,980
exposure to Silicon Valley Bank.

42
00:02:59,980 --> 00:03:04,980
We have been all over the situation, and the short answer is BlockFi is fine.

43
00:03:04,980 --> 00:03:09,980
We have access to cash to operate in the normal course, including paying our

44
00:03:09,980 --> 00:03:11,980
employees and vendors.

45
00:03:11,980 --> 00:03:18,980
And we expect to have access to 37 million of the 278 million at SVB later

46
00:03:18,980 --> 00:03:20,980
today.

47
00:03:20,980 --> 00:03:26,980
Your Honor, the vast majority of the debtors' funds at SVB, approximately 236

48
00:03:26,980 --> 00:03:31,980
million, are invested in highly rated money market funds.

49
00:03:31,980 --> 00:03:38,980
Fifty percent is allocated to the BlackRock Liquidity Fed Fund admin, and 50

50
00:03:38,980 --> 00:03:44,980
percent is allocated to Morgan Stanley ILF government incel, both of which are

51
00:03:44,980 --> 00:03:50,980
invested in government securities, with SVB acting as agent on behalf of

52
00:03:50,980 --> 00:03:52,980
BlockFi.

53
00:03:52,980 --> 00:03:56,980
Once we get access to those money market funds, we will work with the U.S.

54
00:03:56,980 --> 00:03:59,980
Trustee and the Committee to make sure that we are in compliance with Section

55
00:03:59,980 --> 00:04:01,980
345B.

56
00:04:01,980 --> 00:04:06,980
I know the U.S. Trustee filed a motion on Friday, and we have every intention

57
00:04:06,980 --> 00:04:10,980
of complying with our obligations with respect to 345B.

58
00:04:10,980 --> 00:04:14,980
We want to thank the U.S. Trustee and the Committee, who we have been in

59
00:04:14,980 --> 00:04:19,980
constant contact with as the SVB situation developed and over the weekend,

60
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and who we've continued to have productive conversations with leading up to this

61
00:04:24,980 --> 00:04:26,980
morning's hearing.

62
00:04:26,980 --> 00:04:29,980
So, Your Honor, the short answer again is we are fine.

63
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There's nothing to be worried about here.

64
00:04:31,980 --> 00:04:36,980
And again, we thank the Committee and the U.S. Trustee for their cooperation in

65
00:04:36,980 --> 00:04:38,980
this matter.

66
00:04:38,980 --> 00:04:42,980
Once we have access to those funds and we determine next steps in terms of the

67
00:04:42,980 --> 00:04:46,980
bank account and making sure that we're protected and it's in a safe place, we

68
00:04:46,980 --> 00:04:50,980
will update the Court, and I anticipate we'll have news on that, you know,

69
00:04:50,980 --> 00:04:52,980
within a week or so.

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Thank you.

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00:04:54,980 --> 00:04:56,980
I appreciate that.

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00:04:56,980 --> 00:05:01,980
I'm sure it's a significant sigh of relief to those who are listening, who

73
00:05:01,980 --> 00:05:14,980
have an interest in the financial wherewithal of the debtor and are relieved

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00:05:14,980 --> 00:05:21,980
to know that it's not as desperate as it seemed probably to a lot of people in

75
00:05:21,980 --> 00:05:26,980
the room Thursday afternoon and Friday and during the weekend.

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And I do appreciate all Council working together.

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00:05:30,980 --> 00:05:34,980
In that regard, I know there's other matters on for today, but I would like to

78
00:05:34,980 --> 00:05:39,980
give the U.S. Trustee an opportunity if they wish to weigh in on where we stand

79
00:05:39,980 --> 00:05:47,980
again to either supplement or to modify what's been placed on the record.

80
00:05:47,980 --> 00:05:49,980
Good morning, Your Honor.

81
00:05:49,980 --> 00:05:50,980
Thank you.

82
00:05:50,980 --> 00:05:53,980
Jeff Sponder together with Andy Vara, the United States Trustee, and Lauren

83
00:05:53,980 --> 00:05:57,980
Bilsky, all on behalf of Andy Vara, the United States Trustee.

84
00:05:57,980 --> 00:06:01,980
Your Honor, at all levels of the United States Trustee program, we have been

85
00:06:01,980 --> 00:06:06,980
engaged to ensure the state funds are available and protected.

86
00:06:06,980 --> 00:06:09,980
We do appreciate the cooperation of all Council in these cases.

87
00:06:09,980 --> 00:06:13,980
We have worked diligently with debtor and committee Council throughout this

88
00:06:13,980 --> 00:06:18,980
case and especially this weekend, and we'll continue to work with the

89
00:06:18,980 --> 00:06:23,980
debtors as they become 345 compliant so that all the state funds will be

90
00:06:23,980 --> 00:06:24,980
protected.

91
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Thank you.

92
00:06:25,980 --> 00:06:26,980
Thank you.

93
00:06:26,980 --> 00:06:38,980
Would it be best to keep a date going forward for the compliance issues so

94
00:06:38,980 --> 00:06:45,980
that we can have a follow-up conference or if need be, hearing?

95
00:06:45,980 --> 00:06:47,980
Your Honor, Jeff Sponder again from the U.S. Trustee.

96
00:06:47,980 --> 00:06:50,980
I think that would be appropriate.

97
00:06:50,980 --> 00:06:55,980
I know Council for the Debtors is advised within a week, so I don't know if

98
00:06:55,980 --> 00:06:57,980
we have a hearing scheduled.

99
00:06:57,980 --> 00:07:05,980
I think we have a hearing on the 23rd.

100
00:07:05,980 --> 00:07:06,980
Let's see.

101
00:07:06,980 --> 00:07:13,980
We do have, we have you all on for the 23rd, so why don't we just carry the

102
00:07:13,980 --> 00:07:16,980
U.S. Trustee's motion to that date?

103
00:07:16,980 --> 00:07:21,980
We could always adjust the schedule from there if we need more time.

104
00:07:21,980 --> 00:07:30,980
And obviously, again, my thanks to the U.S. Trustee who was able to put this

105
00:07:30,980 --> 00:07:35,980
matter on, get papers filed on short notice on Friday, and we were able to

106
00:07:35,980 --> 00:07:36,980
schedule the hearing.

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If there's a need to do that again, the Court will make itself available,

108
00:07:43,980 --> 00:07:49,980
but otherwise we'll carry the U.S. Trustee's motion to 323 with two other

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00:07:49,980 --> 00:07:52,980
matters that are on.

110
00:07:52,980 --> 00:07:58,980
Then let me, is there anyone else who wants to be heard on the cash management

111
00:07:58,980 --> 00:08:02,980
issues before we move on to other issues?

112
00:08:02,980 --> 00:08:10,980
I see no one, no hands raised, so let me again go to Debtors Council for the

113
00:08:10,980 --> 00:08:12,980
next matter.

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00:08:12,980 --> 00:08:13,980
Thank you, Your Honor.

115
00:08:13,980 --> 00:08:16,980
Christine Okike again on behalf of the debtors.

116
00:08:16,980 --> 00:08:20,980
Your Honor, the next item on the agenda is a status update on the wallet

117
00:08:20,980 --> 00:08:24,980
withdrawal motion, which was filed at Docket Number 121.

118
00:08:24,980 --> 00:08:29,980
So last Wednesday, as Your Honor noted, the debtors filed a joint letter among

119
00:08:29,980 --> 00:08:33,980
the debtors, the committee, and the ad hoc committee of wallet holders to

120
00:08:33,980 --> 00:08:37,980
provide an update to BlockFi's clients with respect to BlockFi's request to

121
00:08:37,980 --> 00:08:41,980
return the digital assets and the wallet accounts as of the platform pause to

122
00:08:41,980 --> 00:08:43,980
their clients as soon as possible.

123
00:08:43,980 --> 00:08:47,980
The debtors understand that our clients want the wallet withdrawal motion

124
00:08:47,980 --> 00:08:49,980
resolved promptly, and so do we.

125
00:08:49,980 --> 00:08:53,980
And we are actively working with the committee, the ad hoc committee, and

126
00:08:53,980 --> 00:08:56,980
deferred 1031 to achieve that goal.

127
00:08:56,980 --> 00:09:00,980
Your Honor, when we filed the wallet withdrawal motion, two things happened.

128
00:09:00,980 --> 00:09:04,980
First, the committee advised the debtors that it was supportive of returning

129
00:09:04,980 --> 00:09:09,980
some wallet holdings to clients, but only if BlockFi clients with those wallet

130
00:09:09,980 --> 00:09:14,980
holdings were not subject to potential avoidance claims or clawbacks.

131
00:09:14,980 --> 00:09:18,980
Determining which clients might be subject to clawbacks is a very complex issue,

132
00:09:18,980 --> 00:09:21,980
and the debtors understand that the committee's diligence with respect to

133
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that is ongoing.

134
00:09:23,980 --> 00:09:28,980
Second, the members of the ad hoc committee and deferred 1031, who are

135
00:09:28,980 --> 00:09:32,980
BlockFi clients who attempted to transfer digital assets from their

136
00:09:32,980 --> 00:09:37,980
interest-bearing accounts or BIAs to wallet after the platform pause, which

137
00:09:37,980 --> 00:09:44,980
was 8.15 p.m. Eastern on November 10, 2022, contended that their holdings

138
00:09:44,980 --> 00:09:49,980
should be treated the same as those clients who had wallet holdings in wallet

139
00:09:49,980 --> 00:09:51,980
at the time of the platform pause.

140
00:09:51,980 --> 00:09:55,980
Both the debtors and the committee dispute that position, but the ad hoc

141
00:09:55,980 --> 00:09:59,980
committee and deferred 1031 have the right to have their arguments heard

142
00:09:59,980 --> 00:10:01,980
before the court.

143
00:10:01,980 --> 00:10:05,980
The debtors have provided the ad hoc committee and deferred 1031 with a

144
00:10:05,980 --> 00:10:07,980
substantial amount of information.

145
00:10:07,980 --> 00:10:11,980
We responded to about 60 questions that they had with respect to the platform

146
00:10:11,980 --> 00:10:15,980
pause and actions that the debtors took to help resolve this issue.

147
00:10:15,980 --> 00:10:19,980
But the debtors understand that the ad hoc committee and deferred 1031's

148
00:10:19,980 --> 00:10:21,980
diligence also continues.

149
00:10:21,980 --> 00:10:26,980
There are no open diligence requests from our perspective, and to the extent

150
00:10:26,980 --> 00:10:29,980
that they do have additional diligence requests, we would ask that they

151
00:10:29,980 --> 00:10:31,980
provide them promptly.

152
00:10:31,980 --> 00:10:36,980
Your Honor, we've reserved time on the court's calendar on April 19th to

153
00:10:36,980 --> 00:10:41,980
resolve the issue of whether the attempted transfers of the ad hoc committee

154
00:10:41,980 --> 00:10:47,980
and deferred 1031 after the platform pause should be treated as wallet holdings

155
00:10:47,980 --> 00:10:49,980
as of the platform pause.

156
00:10:49,980 --> 00:10:53,980
We really view that as an initial issue that should be decided before you even

157
00:10:53,980 --> 00:10:58,980
get to the question of dealing with potential preferences for people who are

158
00:10:58,980 --> 00:11:00,980
in wallet.

159
00:11:00,980 --> 00:11:05,980
We expect to go forward on April 19th, absent a resolution or agreement between

160
00:11:05,980 --> 00:11:09,980
the parties before then, and we're happy to continue to work with the ad hoc

161
00:11:09,980 --> 00:11:15,980
group as well as deferred 1031 to reach a consensual resolution.

162
00:11:15,980 --> 00:11:19,980
So I believe that's document number 559, the pause motion.

163
00:11:19,980 --> 00:11:25,980
So that's going to be, in essence, that's going ahead on the 19th to be argued

164
00:11:25,980 --> 00:11:27,980
unless there's a resolution.

165
00:11:27,980 --> 00:11:28,980
Correct, Your Honor.

166
00:11:28,980 --> 00:11:29,980
Okay, great.

167
00:11:29,980 --> 00:11:34,980
So we will submit a supplemental briefing schedule to Your Honor.

168
00:11:34,980 --> 00:11:39,980
We continue to have discussions with the committee, the ad hoc group, as well as

169
00:11:39,980 --> 00:11:42,980
deferred 1031 on that schedule.

170
00:11:42,980 --> 00:11:43,980
All right, great.

171
00:11:43,980 --> 00:11:44,980
Thank you.

172
00:11:44,980 --> 00:11:51,980
Does the committee wish to be heard?

173
00:11:51,980 --> 00:11:52,980
Good morning, Your Honor.

174
00:11:52,980 --> 00:11:55,980
Kenneth Ouellette of Brown Brodnik for the committee.

175
00:11:55,980 --> 00:12:00,980
Just to reiterate, the committee does view it as important to return these funds

176
00:12:00,980 --> 00:12:05,980
to wallet holders as quickly as possible as soon as it can be determined by Your

177
00:12:05,980 --> 00:12:11,980
Honor or hopefully by agreement who the wallet holders are.

178
00:12:11,980 --> 00:12:13,980
Ms. Okike mentioned the preference diligence.

179
00:12:13,980 --> 00:12:19,980
We fully expect that that will be done by April 19th, and the committee has

180
00:12:19,980 --> 00:12:25,980
completed its diligence into all of the factual issues surrounding the issues to

181
00:12:25,980 --> 00:12:28,980
be decided on the 19th.

182
00:12:28,980 --> 00:12:32,980
And unless Your Honor has any other questions, thank you for your time.

183
00:12:32,980 --> 00:12:33,980
No, thank you.

184
00:12:33,980 --> 00:12:34,980
Thank you, Mr. Ouellette.

185
00:12:34,980 --> 00:12:40,980
Ms. Kofsky, I see your hand raised.

186
00:12:40,980 --> 00:12:41,980
Thank you, Your Honor.

187
00:12:41,980 --> 00:12:44,980
Deb Kofsky, General Pepper for the ad hoc committee.

188
00:12:44,980 --> 00:12:49,980
I wanted to just clarify a couple of things for the record.

189
00:12:49,980 --> 00:12:55,980
One is that people referred to my client's transfers as attempted transfers.

190
00:12:55,980 --> 00:12:58,980
Obviously, we dispute that characterization.

191
00:12:58,980 --> 00:13:02,980
With respect to diligence, that remains ongoing.

192
00:13:02,980 --> 00:13:07,980
The veterans have answered some but not all of the questions that were posed to them.

193
00:13:07,980 --> 00:13:12,980
We appreciate that information, but our diligence is ongoing, and we are attempting

194
00:13:12,980 --> 00:13:18,980
to work out a schedule that enables the ad hoc committee and the firm to review

195
00:13:18,980 --> 00:13:24,980
and take appropriate discovery in order to be able to put all of the facts before

196
00:13:24,980 --> 00:13:25,980
Your Honor.

197
00:13:25,980 --> 00:13:30,980
And while we have reserved time on April 19th, the due diligence seeking extension

198
00:13:30,980 --> 00:13:36,980
of that date should be necessary in order for us to complete our discovery.

199
00:13:36,980 --> 00:13:38,980
All right.

200
00:13:38,980 --> 00:13:40,980
I hear you.

201
00:13:40,980 --> 00:13:45,980
Obviously, with respect to outstanding discovery, I'll just ask that the Council do

202
00:13:45,980 --> 00:13:51,980
their best to confer as quickly as possible so we can move the process and not have

203
00:13:51,980 --> 00:13:53,980
a holdup over discovery issues.

204
00:13:53,980 --> 00:13:55,980
All right.

205
00:13:55,980 --> 00:13:56,980
I don't see it.

206
00:13:56,980 --> 00:13:57,980
Mr. Stark?

207
00:13:57,980 --> 00:14:02,980
Thank you, Your Honor.

208
00:14:02,980 --> 00:14:06,980
With Your Honor's indulgence, I know that normally we handle each matter with one lawyer,

209
00:14:06,980 --> 00:14:08,980
but I want to be constructive.

210
00:14:08,980 --> 00:14:09,980
That's fine.

211
00:14:09,980 --> 00:14:10,980
Thank you.

212
00:14:10,980 --> 00:14:18,980
It's very important to the Committee that issues move along quickly and that this case

213
00:14:18,980 --> 00:14:21,980
moves along quickly, and this is an important issue.

214
00:14:21,980 --> 00:14:26,980
And I make and I have absolute respect for the position Ms. Cowsky is raising.

215
00:14:26,980 --> 00:14:32,980
I just want to rise, put a stake in the ground for maybe reverse, come back to it at a different

216
00:14:32,980 --> 00:14:33,980
date.

217
00:14:33,980 --> 00:14:34,980
We want to move this issue along.

218
00:14:34,980 --> 00:14:39,980
So I know we got our diligence done quickly, she has a job to do, and I fully respect the

219
00:14:39,980 --> 00:14:40,980
job.

220
00:14:40,980 --> 00:14:45,980
I just, if there are issues in terms of discovery, if there are issues in terms of diligence,

221
00:14:45,980 --> 00:14:50,980
let's learn about them now, let's obviate them now so we can resolve this issue once and

222
00:14:50,980 --> 00:14:54,980
for all in due course, in the due course being on the nearer side, not the farther side.

223
00:14:54,980 --> 00:14:56,980
So that's all I wanted to say.

224
00:14:56,980 --> 00:14:57,980
No, I appreciate that.

225
00:14:57,980 --> 00:14:58,980
I was going to follow up.

226
00:14:58,980 --> 00:14:59,980
I thank you.

227
00:14:59,980 --> 00:15:09,980
Follow up, I'd rather be that we have quick calls to resolve discovery issues in the short

228
00:15:09,980 --> 00:15:10,980
term.

229
00:15:10,980 --> 00:15:15,980
The Court will always make itself available for a call, and we don't need motion practice,

230
00:15:15,980 --> 00:15:20,980
we don't need letter writing as much as just reach out and we can talk about these issues.

231
00:15:20,980 --> 00:15:21,980
All right.

232
00:15:21,980 --> 00:15:22,980
Thank you.

233
00:15:22,980 --> 00:15:24,980
Thank you Ms. Cowsky.

234
00:15:24,980 --> 00:15:32,980
All right, I think Mr. Kanowitz, we come to the emergent matter?

235
00:15:32,980 --> 00:15:36,980
Yes, Your Honor, may it please the Court, Richard Kanowitz of Haynes and Boone, co-counsel for

236
00:15:36,980 --> 00:15:38,980
the debtors and debtors in possession.

237
00:15:38,980 --> 00:15:42,980
Your Honor, I just wanted to give you a quick status of the emergent matters.

238
00:15:42,980 --> 00:15:46,980
There were a lot of things going on behind the scenes that I want you to be apprised of

239
00:15:46,980 --> 00:15:50,980
so that if and when we get in front of Your Honor, you're not surprised.

240
00:15:50,980 --> 00:15:56,980
So, as you see, as you entered the order on docket 61, we extended the time for Marik's

241
00:15:56,980 --> 00:15:58,980
to move our answer to 5-1.

242
00:15:58,980 --> 00:16:06,980
Likewise, in docket number 60, we extended the pretrial conference date to April 19th.

243
00:16:06,980 --> 00:16:08,980
Expect that potentially to move again.

244
00:16:08,980 --> 00:16:09,980
That was one of the matters I was going to raise.

245
00:16:09,980 --> 00:16:13,980
It doesn't make much sense if we're extending the answer to 5-1.

246
00:16:13,980 --> 00:16:18,980
We were going to take it in chunks because, you know, tomorrow is a trial in the emergent

247
00:16:18,980 --> 00:16:20,980
bankruptcy case.

248
00:16:20,980 --> 00:16:22,980
Let me get to that point.

249
00:16:22,980 --> 00:16:27,980
So, you know, coming out of the hearing on January 9th, you directed us to file an amended

250
00:16:27,980 --> 00:16:29,980
complaint, and we worked on that.

251
00:16:29,980 --> 00:16:34,980
And the DOJ took interest in that and asked us for a copy, and we sent it to them.

252
00:16:34,980 --> 00:16:36,980
And that took weeks of discussions with them.

253
00:16:36,980 --> 00:16:41,980
And coming out of their review, they said to us in no uncertain terms, your amended

254
00:16:41,980 --> 00:16:47,980
complaint interferes with the criminal prosecution of Sam Beckman Fried and other

255
00:16:47,980 --> 00:16:53,980
investigations and potential prosecutions, and that you also, by virtue of some of the

256
00:16:53,980 --> 00:16:57,980
issues raised in the adversary proceeding complaint, interfere with what they believe is the

257
00:16:57,980 --> 00:17:02,980
current civil and criminal forfeiture proceedings.

258
00:17:02,980 --> 00:17:04,980
We obviously looked at the law.

259
00:17:04,980 --> 00:17:06,980
We came to a conclusion.

260
00:17:06,980 --> 00:17:12,980
And the outcome of our discussions, because it's not an agreement with the DOJ, but you

261
00:17:12,980 --> 00:17:16,980
have discussions with the DOJ, and they tell you what they think, and you decide what to

262
00:17:16,980 --> 00:17:17,980
do next.

263
00:17:17,980 --> 00:17:22,980
Well, what we decided to do was file the amended complaint, but then ask your honor to stay

264
00:17:22,980 --> 00:17:27,980
it, right, and go through those issues as to why it matters for us to file an amended

265
00:17:27,980 --> 00:17:33,980
complaint and for us to stay it pending prosecution of Sam Beckman Fried and the civil and criminal

266
00:17:33,980 --> 00:17:38,980
forfeiture proceedings, which unfortunately will be many years down the road and occur

267
00:17:38,980 --> 00:17:43,980
in the Southern District in New York if, in fact, we agree and, you know, we looked at

268
00:17:43,980 --> 00:17:47,980
the law, that the Southern District in New York really has jurisdiction over the disputes,

269
00:17:47,980 --> 00:17:49,980
all of the disputes.

270
00:17:49,980 --> 00:17:54,980
We never got to that point of filing and seeking a stay because Emergent filed the bankruptcy.

271
00:17:54,980 --> 00:18:00,980
So we have taken the next step to move to dismiss the Emergent bankruptcy case for a

272
00:18:00,980 --> 00:18:02,980
host of reasons that are public records.

273
00:18:02,980 --> 00:18:05,980
I don't need to argue them here or point them out.

274
00:18:05,980 --> 00:18:10,980
Obviously, we're raising two key issues, the good faith of that filing by the JPLs in

275
00:18:10,980 --> 00:18:15,980
Antigua as well as the fact that the money has been and the assets have been seized and

276
00:18:15,980 --> 00:18:20,980
if the government is right, and I believe they are, then these disputes are not going to

277
00:18:20,980 --> 00:18:24,980
happen in any bankruptcy court, but they're going to happen in the Southern District in

278
00:18:24,980 --> 00:18:26,980
New York at some time in the future.

279
00:18:26,980 --> 00:18:31,980
So we're going tomorrow and we're going to have a whole trial, witnesses, et cetera.

280
00:18:31,980 --> 00:18:33,980
We'll see what Judge Dorsey does.

281
00:18:33,980 --> 00:18:39,980
In the meantime, we are talking to the DOJ and Emergent, and I believe FTX is also involved

282
00:18:39,980 --> 00:18:42,980
because they've tried to intervene in our motion to dismiss.

283
00:18:42,980 --> 00:18:47,980
To see maybe fiduciaries could come to the table and actually figure out the right path

284
00:18:47,980 --> 00:18:52,980
to not waste legal fees, estate resources, et cetera.

285
00:18:52,980 --> 00:18:54,980
I'm hopeful we get there.

286
00:18:54,980 --> 00:18:58,980
If not, well, we'll have our trial tomorrow and we'll proceed accordingly.

287
00:18:58,980 --> 00:19:02,980
The one thing that I want to put on the record that's crystal clear, Your Honor was very,

288
00:19:02,980 --> 00:19:06,980
very clear that you believe you have jurisdiction over the debtor's interest in the

289
00:19:06,980 --> 00:19:10,980
guarantee and pledge agreement and the shares to the extent now you have it or don't have it

290
00:19:10,980 --> 00:19:12,980
by virtue of the seizure.

291
00:19:12,980 --> 00:19:16,980
We're going to defend that jurisdiction and we're going to defend property of the estate

292
00:19:16,980 --> 00:19:18,980
no matter where it's litigated.

293
00:19:18,980 --> 00:19:22,980
And I just wanted to leave that on the record so that everyone is clear that we are vigilant

294
00:19:22,980 --> 00:19:30,980
in protecting what we believe are the victims of the FTX Sam Bankman Fried slash emergent fraud.

295
00:19:30,980 --> 00:19:32,980
Thank you, Mr. Kennewith.

296
00:19:32,980 --> 00:19:35,980
I appreciate the update.

297
00:19:35,980 --> 00:19:39,980
I don't see anybody on Zoom looking to comment further.

298
00:19:39,980 --> 00:19:41,980
I don't see any raised hands.

299
00:19:41,980 --> 00:19:51,980
Let me just ask with respect to that pretrial date, do you want to leave it on for now or should I be moving it into May?

300
00:19:51,980 --> 00:19:56,980
We didn't have a May court hearing to suggest that.

301
00:19:56,980 --> 00:20:01,980
But once we do establish it, yes, we should make an application, however you want it on the record,

302
00:20:01,980 --> 00:20:09,980
we did let or in pleading like we did last time to move it, but yes, it has to be moved pending what happens in emergent own bankruptcy case.

303
00:20:09,980 --> 00:20:11,980
All right. We're going to get to scheduling.

304
00:20:11,980 --> 00:20:16,980
I have some suggested dates and we'll talk about it before the end of the hearing this morning.

305
00:20:16,980 --> 00:20:17,980
Thank you.

306
00:20:17,980 --> 00:20:19,980
I'll see the podium.

307
00:20:19,980 --> 00:20:20,980
Ms. Chavez.

308
00:20:20,980 --> 00:20:26,980
Good morning.

309
00:20:26,980 --> 00:20:27,980
Good morning, Your Honor.

310
00:20:27,980 --> 00:20:29,980
Jordan Chavez of Haynes and Boone on behalf of the debtors.

311
00:20:29,980 --> 00:20:35,980
Just two procedural motions that are both uncontested that we wanted to take up with your honor today.

312
00:20:35,980 --> 00:20:44,980
The first one is the motion we filed to extend the removal deadline at docket number 500, which was followed by this first bridge order at docket number 514.

313
00:20:44,980 --> 00:20:56,980
In that motion, we're asking for an extension of the removal deadline to May 27th, 2023, and we received no objections or informal comments to this motion or the proposed order.

314
00:20:56,980 --> 00:21:03,980
So we would ask that your honor grant the motion and we will get with local council to submit the proposed order to chambers.

315
00:21:03,980 --> 00:21:04,980
That's fine.

316
00:21:04,980 --> 00:21:05,980
I've gone through it.

317
00:21:05,980 --> 00:21:07,980
There are no issues with it.

318
00:21:07,980 --> 00:21:11,980
Market granted and will market order to be submitted.

319
00:21:11,980 --> 00:21:12,980
Thank you, Your Honor.

320
00:21:12,980 --> 00:21:23,980
The second motion is the motion for the claims procedures that we filed at docket number 535, which is designed to streamline the claims reconciliation and objection process.

321
00:21:23,980 --> 00:21:29,980
The proposed order that we filed with the motion already incorporated the constructive comments that we received from committee council.

322
00:21:29,980 --> 00:21:36,980
And then we received some informal comments after filing the motion from Arch, which is the one of the debtors insurers.

323
00:21:36,980 --> 00:21:41,980
And we filed a notice of revised proposed order for that at docket number 586.

324
00:21:41,980 --> 00:21:45,980
There were no additional comments and no other objections received.

325
00:21:45,980 --> 00:21:56,980
And the only change that we reflected in the revised proposed order was we had a basis for an objection if the insurers were obligated to make the payment rather than the debtors.

326
00:21:56,980 --> 00:22:04,980
And the insurer understandably just wanted a clarification that that would only be after its termination by this court or another court of competent jurisdiction.

327
00:22:04,980 --> 00:22:07,980
So with that, I would ask your honor to grant the motion.

328
00:22:07,980 --> 00:22:11,980
And again, we will get with local council to submit the proposed order to chambers.

329
00:22:11,980 --> 00:22:12,980
I only had one question.

330
00:22:12,980 --> 00:22:19,980
I think it all makes sense and how it's laid out.

331
00:22:19,980 --> 00:22:23,980
Service of the omnibus objections.

332
00:22:23,980 --> 00:22:29,980
And we're relaxing our local and the federal rule as far as grouping in hundreds and the like.

333
00:22:29,980 --> 00:22:33,980
But how is service being undertaken on an individual claimant?

334
00:22:33,980 --> 00:22:40,980
I thought I saw read through it and it referenced both mail and email.

335
00:22:40,980 --> 00:22:46,980
Can you be more specific as to as to how what's the intention as far as service on the claimants?

336
00:22:46,980 --> 00:22:54,980
Yes, your honor, to the extent we have both mail and email information, we are having pro served them via both methods of process.

337
00:22:54,980 --> 00:22:58,980
And so that would be the measure we would take here as well.

338
00:22:58,980 --> 00:23:07,980
Given the interim redaction order, we are serving them directly and trying to keep all of their personal information confidential while doing so.

339
00:23:07,980 --> 00:23:23,980
And I understood in reading through your also trying to make a point to the to the claimants that they should in their responses respect the confidentiality as well and redaction.

340
00:23:23,980 --> 00:23:26,980
It may be that individuals need some assistance.

341
00:23:26,980 --> 00:23:32,980
And I think you included contact information as well, both at Kroll and at the firms.

342
00:23:32,980 --> 00:23:33,980
Correct?

343
00:23:33,980 --> 00:23:42,980
Yes, your honor, we included my direct contact information as well as one of my colleagues, Mr. Zavala, so they can directly reach out to us if they have questions or need assistance.

344
00:23:42,980 --> 00:23:48,980
And of course, to hopefully informally resolve the objections so we don't have to take up court time.

345
00:23:48,980 --> 00:23:54,980
I'm just judging from some of the email that my chambers received is from claimants.

346
00:23:54,980 --> 00:24:03,980
Unfortunately, they claimants tend to be more liberal or loose unintentionally with their own personal identifiable information.

347
00:24:03,980 --> 00:24:06,980
We end up sealing and redacting their information.

348
00:24:06,980 --> 00:24:09,980
We're not putting on the docket to protect them.

349
00:24:09,980 --> 00:24:12,980
So it's a difficult issue.

350
00:24:12,980 --> 00:24:21,980
But I think the notices are there to to to admonish them to be careful on their own end.

351
00:24:21,980 --> 00:24:23,980
I don't have any other issues.

352
00:24:23,980 --> 00:24:27,980
Anyone in court have any issues on the objection claims procedure motion?

353
00:24:27,980 --> 00:24:29,980
I know you've gone through with all the parties.

354
00:24:29,980 --> 00:24:31,980
I've seen no questions.

355
00:24:31,980 --> 00:24:34,980
So it'll be ordered to be submitted.

356
00:24:34,980 --> 00:24:35,980
Yes, your honor.

357
00:24:35,980 --> 00:24:36,980
All right.

358
00:24:36,980 --> 00:24:38,980
Thank you.

359
00:24:38,980 --> 00:24:39,980
All right.

360
00:24:39,980 --> 00:24:43,980
That goes through, I think, what we had on our agenda.

361
00:24:43,980 --> 00:24:49,980
Well, Mr. Stark.

362
00:24:49,980 --> 00:24:58,980
Your Honor, allow me to spend a minute on something that you're on just touched upon, but you're on touched upon at the beginning of the hearing as well.

363
00:24:58,980 --> 00:24:59,980
And I wanted to do something.

364
00:24:59,980 --> 00:25:00,980
Your Honor will allow me.

365
00:25:00,980 --> 00:25:01,980
Sure.

366
00:25:01,980 --> 00:25:14,980
Your Honor mentioned the letter that the debtors circulated to the customers and your honor made reference again to the customer predator outreaches to the court chambers.

367
00:25:14,980 --> 00:25:19,980
I'd like to address that just for a moment.

368
00:25:19,980 --> 00:25:31,980
We as a committee acknowledge not only do we have a statutory and fiduciary obligation to talk to customers and credit creditors in the normal case.

369
00:25:31,980 --> 00:25:33,980
This is not the normal case.

370
00:25:33,980 --> 00:25:41,980
Customers and creditors here lost their lives, savings, lost their wages and their worry.

371
00:25:41,980 --> 00:25:42,980
And we get that.

372
00:25:42,980 --> 00:25:46,980
We've been in existence, at least with professionals, for under three months.

373
00:25:46,980 --> 00:25:51,980
It seems like for the people who lost their money, that seems like an eternity and we're very sensitive to that.

374
00:25:51,980 --> 00:26:06,980
But for bankruptcy, there's a lot that has to go on in the initial stages of bankruptcy and especially in a sensitive case, disables the kind of direct communication that I know folks are really thirsting for and need.

375
00:26:06,980 --> 00:26:07,980
We set up a website.

376
00:26:07,980 --> 00:26:09,980
We have a Twitter feed.

377
00:26:09,980 --> 00:26:11,980
But we acknowledge.

378
00:26:11,980 --> 00:26:22,980
And we have to acknowledge the number of inbound calls and emails that I know your honors chambers have been receiving.

379
00:26:22,980 --> 00:26:24,980
We're going to we want to put a stop to that.

380
00:26:24,980 --> 00:26:26,980
We want to help the community more.

381
00:26:26,980 --> 00:26:34,980
The first thing I can do right now is on the record to those who are listening in, my name is Robert Stark.

382
00:26:34,980 --> 00:26:36,980
I work at a firm, Brown-Rudnick.

383
00:26:36,980 --> 00:26:39,980
My email is rstark at brownrudnick.com.

384
00:26:39,980 --> 00:26:44,980
My telephone number is 212-209-4862.

385
00:26:44,980 --> 00:26:55,980
Any customer or creditor who is listening in, who wants to find out information about this case, please call or email me and we will respond within 48 hours.

386
00:26:55,980 --> 00:26:57,980
It is not the court's job to respond.

387
00:26:57,980 --> 00:26:58,980
It is mine.

388
00:26:58,980 --> 00:27:00,980
And we will do that.

389
00:27:00,980 --> 00:27:08,980
The second thing that I can do for your honor and for all those who are listening, the committee understands and spent an awful lot of time in the last two weeks specifically.

390
00:27:08,980 --> 00:27:15,980
To come forward with a program for reaching out to the customers and consumers.

391
00:27:15,980 --> 00:27:26,980
There are a whole host of different ways that we could try to do it from town hall meetings to Reddit Q&As to inbounds and outflows.

392
00:27:26,980 --> 00:27:28,980
We have to be thoughtful.

393
00:27:28,980 --> 00:27:29,980
We have to be disciplined.

394
00:27:29,980 --> 00:27:30,980
There's an awful lot going on.

395
00:27:30,980 --> 00:27:32,980
Again, it's a very sensitive case.

396
00:27:32,980 --> 00:27:35,980
We have our own confidentiality issues and fiduciary issues.

397
00:27:35,980 --> 00:27:38,980
But we know that there's more that we can be doing.

398
00:27:38,980 --> 00:27:52,980
And so we are right about to launch, but for the issues of last week, we probably would have happened last week, we're about to launch a program where we're going to be much more communicative with the community outside.

399
00:27:52,980 --> 00:27:55,980
And they will have much easier access to us.

400
00:27:55,980 --> 00:27:56,980
They will know our names.

401
00:27:56,980 --> 00:27:58,980
They will know that we're standing by.

402
00:27:58,980 --> 00:28:01,980
They will have information, much more information.

403
00:28:01,980 --> 00:28:07,980
But it won't be sensitive information that we believe might inhibit our ability to resolve this case quickly.

404
00:28:07,980 --> 00:28:10,980
But they will have greater understanding and less confusion.

405
00:28:10,980 --> 00:28:12,980
So that's about to get launched right now.

406
00:28:12,980 --> 00:28:15,980
I just want your honor and everyone listening to know that.

407
00:28:15,980 --> 00:28:16,980
That's great.

408
00:28:16,980 --> 00:28:17,980
I appreciate that, Mr.

409
00:28:17,980 --> 00:28:18,980
Stark.

410
00:28:17,980 --> 00:28:20,980
I know my law clerks appreciate it.

411
00:28:20,980 --> 00:28:22,980
Reducing the burdens on the court.

412
00:28:22,980 --> 00:28:28,980
But because we would just defer to you all and send the names along, I think.

413
00:28:28,980 --> 00:28:31,980
I look forward to the enhanced communication.

414
00:28:31,980 --> 00:28:33,980
I think it will be worthwhile.

415
00:28:33,980 --> 00:28:34,980
I appreciate it.

416
00:28:34,980 --> 00:28:35,980
Thank you.

417
00:28:35,980 --> 00:28:38,980
Let's talk about some calendar events.

418
00:28:38,980 --> 00:28:39,980
Yeah.

419
00:28:39,980 --> 00:28:41,980
One item to tag along.

420
00:28:41,980 --> 00:28:42,980
Sure.

421
00:28:42,980 --> 00:28:46,980
We appreciate the committee, especially Mr.

422
00:28:46,980 --> 00:28:49,980
Stark, taking the laboring work on communicating with his constituency.

423
00:28:49,980 --> 00:29:04,980
But just so you know, we get daily inbound, both at Haynes and Moon, Kirkman and Ellis, and we respond by email and we have a team working to get those creditors information about the CRO website, the process for filing proofs of claim.

424
00:29:04,980 --> 00:29:11,980
So the debtors of state recognizes that this is a, I would say, a choppy process, but one that needs to have all resources devoted.

425
00:29:11,980 --> 00:29:20,980
So it's transparent and people have confidence that this case is moving forward and one day, you know, they will be taken care of as best we can.

426
00:29:20,980 --> 00:29:22,980
Now, I appreciate that.

427
00:29:22,980 --> 00:29:24,980
Appreciate the debtors efforts.

428
00:29:24,980 --> 00:29:31,980
I just remarked the Chapter 11 process practices certainly changed in a decade.

429
00:29:31,980 --> 00:29:45,980
The ability through the use of these claims agents, the websites, what I can't help but see and hear on YouTube and Twitter, it changes the landscape.

430
00:29:45,980 --> 00:29:54,980
But I think for the better and transparency, even the ability to make our hearings available on Zoom.

431
00:29:54,980 --> 00:29:58,980
So I thank the professionals for their work.

432
00:29:58,980 --> 00:30:02,980
I know it's difficult given that these are personal.

433
00:30:02,980 --> 00:30:05,980
This impacts the lives of many.

434
00:30:05,980 --> 00:30:06,980
Thank you.

435
00:30:06,980 --> 00:30:07,980
You're welcome.

436
00:30:07,980 --> 00:30:16,980
On behalf of the state and all the professionals, we do appreciate Chambers dealing with these issues and we're happy to be as responsible as you want us to be in connection with inbounds to the court.

437
00:30:16,980 --> 00:30:17,980
Great.

438
00:30:17,980 --> 00:30:18,980
All right.

439
00:30:18,980 --> 00:30:19,980
Thank you.

440
00:30:19,980 --> 00:30:20,980
Thank you again.

441
00:30:20,980 --> 00:30:27,980
So let me go through what I have coming up and you can all correct me where we've missed something.

442
00:30:27,980 --> 00:30:31,980
Our next date is March 23rd.

443
00:30:31,980 --> 00:30:38,980
We have two matters that have been scheduled, the sale motion and the extension of time to assume or reject.

444
00:30:38,980 --> 00:30:40,980
I think that's five seventy one and five seventy two.

445
00:30:40,980 --> 00:30:43,980
Those are still scheduled for March 23rd.

446
00:30:43,980 --> 00:30:51,980
We have added the carry trustee three forty five motion.

447
00:30:51,980 --> 00:31:01,980
The next date after that is April 19th in which we have what I call the pause motion as well as the first.

448
00:31:01,980 --> 00:31:09,980
That's number five fifty nine and the first omnibus claims objection motion that was filed.

449
00:31:09,980 --> 00:31:13,980
That's five seventy three.

450
00:31:13,980 --> 00:31:22,980
And then there's another motion, Your Honor, where we're seeking to return the ACH payments that are held by scratch to customers in California.

451
00:31:22,980 --> 00:31:28,980
Correct.

452
00:31:28,980 --> 00:31:35,980
Oh, and then it's anticipated that that date will also be a motion for exclusivity to extend the debtors.

453
00:31:35,980 --> 00:31:36,980
All right.

454
00:31:36,980 --> 00:31:41,980
So a motion will be filed in due course.

455
00:31:41,980 --> 00:31:45,980
Those are all intended for four nineteen.

456
00:31:45,980 --> 00:31:51,980
We have a date that I've converted to an omnibus date.

457
00:31:51,980 --> 00:31:57,980
It was the date for the initial disclosure statement and disclosure statement hearing.

458
00:31:57,980 --> 00:32:00,980
That's May 8th.

459
00:32:00,980 --> 00:32:01,980
That's right.

460
00:32:01,980 --> 00:32:04,980
No, we need May dates.

461
00:32:04,980 --> 00:32:11,980
I just turned that May 8th date into an omnibus date, so that's available for parties.

462
00:32:11,980 --> 00:32:16,980
And.

463
00:32:16,980 --> 00:32:18,980
We have to place.

464
00:32:18,980 --> 00:32:26,980
We have what I'll call the redaction motions, including the confidential party.

465
00:32:26,980 --> 00:32:38,980
It's early on number four on the docket as well as I believe one twenty seven confidential party status and also I think.

466
00:32:38,980 --> 00:32:42,980
Redaction relative to Kroll number four forty three.

467
00:32:42,980 --> 00:32:48,980
Those three redaction motions, ceiling motions, we need to put on a date.

468
00:32:48,980 --> 00:32:52,980
So we have now through we have four nineteen.

469
00:32:52,980 --> 00:32:57,980
We have through five eight and I can make two other dates available in May.

470
00:32:57,980 --> 00:32:59,980
Do you have a preference?

471
00:32:59,980 --> 00:33:01,980
I think I think May is fine.

472
00:33:01,980 --> 00:33:03,980
Then we'll we'll carry those.

473
00:33:03,980 --> 00:33:10,980
Yeah, I could give you a status update as to the counterparty ceiling as well as the redaction.

474
00:33:10,980 --> 00:33:12,980
Mr. Sponsor.

475
00:33:12,980 --> 00:33:15,980
There is sneaking up on me.

476
00:33:15,980 --> 00:33:26,980
Yeah, so the P.I. redaction motion obviously huge concern for not only the debtors, but the committee as well as the ad hoc group who file jointers.

477
00:33:26,980 --> 00:33:28,980
We'll try to have a discussion with the U.S.

478
00:33:28,980 --> 00:33:29,980
to see if we could resolve it.

479
00:33:29,980 --> 00:33:34,980
If not, we are going to have to have a hearing as to the counterparty redaction motion.

480
00:33:34,980 --> 00:33:35,980
What we agreed to with the U.S.

481
00:33:35,980 --> 00:33:44,980
trustee for the adjournment is we'll take it in chunks, meaning once we have completed a sale and the counterparty disclosure is not any more.

482
00:33:44,980 --> 00:33:56,980
Prejudicial to the to the estate in the process will will file supplemental retention declarations and all those things to make those disclosures.

483
00:33:56,980 --> 00:34:02,980
The issue becomes a lot of professionals who are going to file supplemental papers.

484
00:34:02,980 --> 00:34:09,980
So we've got to work out a process so that we don't have 20 filings for every minor transaction.

485
00:34:09,980 --> 00:34:23,980
So we got to figure that one out, but that's our goal is on a rolling basis to actually make those disclosures when they're not prejudicial to the estate of the counterparties who are no longer vying for state assets in one way or another.

486
00:34:23,980 --> 00:34:25,980
So I think carrying it to the eight is important.

487
00:34:25,980 --> 00:34:31,980
That particular counterparty ceiling motion may get kicked again based on what's happening.

488
00:34:31,980 --> 00:34:38,980
And if we don't come to an agreement on the P.I. redaction motion in whole or part, we're probably going to have to have a hearing on it.

489
00:34:38,980 --> 00:34:54,980
Fair enough witnesses then docket number matters reflected by docket numbers for one twenty seven and four forty three will be carried to five eight at ten o'clock.

490
00:34:54,980 --> 00:35:01,980
And then as far as other May dates, I have made it probably doesn't make sense to have one a week later.

491
00:35:01,980 --> 00:35:06,980
Five fifteen five fifteen and five twenty nine available.

492
00:35:06,980 --> 00:35:10,980
I think we should hold the five twenty nine just in case.

493
00:35:10,980 --> 00:35:17,980
Reserve it because you know if if I get booked, you know, future filing, it's Memorial Day.

494
00:35:17,980 --> 00:35:21,980
Your Honor, it's Memorial Day Memorial Day.

495
00:35:21,980 --> 00:35:24,980
That's a problem.

496
00:35:24,980 --> 00:35:26,980
Well, hopefully I'll be on a golf course somewhere.

497
00:35:26,980 --> 00:35:37,980
Then let's see.

498
00:35:37,980 --> 00:35:47,980
Well, we could do five twenty two in the afternoon or then the next Monday is six five June 5th.

499
00:35:47,980 --> 00:35:49,980
Trying to spread it out.

500
00:35:49,980 --> 00:35:53,980
What when we do six five if we need to come back to court?

501
00:35:53,980 --> 00:36:00,980
You know, some of these hearings may very well be zoom as opposed to being in person while we like being in person to the extent we need really.

502
00:36:00,980 --> 00:36:03,980
We could always set something up.

503
00:36:03,980 --> 00:36:05,980
That's fine.

504
00:36:05,980 --> 00:36:14,980
And to the extent that emergent matters may arise, we'll schedule it either on my motion day, normal motion day or as needed.

505
00:36:14,980 --> 00:36:15,980
Yeah.

506
00:36:15,980 --> 00:36:22,980
So just to bring something to the court's attention on the record, two class action complaints were filed,

507
00:36:22,980 --> 00:36:33,980
some of which have been served the debtor intends on filing today an adversary proceeding complaint seeking to stay those pending confirmation in the usual course under one oh five three sixty two.

508
00:36:33,980 --> 00:36:40,980
And for all the arguments that have been made before we get to our complaint file that others have made,

509
00:36:40,980 --> 00:36:43,980
you know, we're going to reach out to the plaintiff firms who started the class action lawsuits.

510
00:36:43,980 --> 00:36:47,980
There are two, one in Jersey and the district court and one in Massachusetts.

511
00:36:47,980 --> 00:36:54,980
And we are going to see if they will voluntarily stay these proceedings, whether we do it in chunks or whether we do it wholesale.

512
00:36:54,980 --> 00:36:56,980
You know, we'll we'll discuss it with them.

513
00:36:56,980 --> 00:37:07,980
But if they do not agree to avoid prejudice to the estate and any defaults or admissions, which we believe is prejudicial, we will come before your honor seeking a TRO in first instance.

514
00:37:07,980 --> 00:37:11,980
So that might be later on this week, depending on how our discussions go.

515
00:37:11,980 --> 00:37:18,980
And we just wanted to alert your honor because we may be making that request and then your honor could direct whether that be in person or by zoom.

516
00:37:18,980 --> 00:37:25,980
All right, great. Then we'll see if there's a need and then we'll decide how to go about as far as the hearing.

517
00:37:25,980 --> 00:37:29,980
I would anticipate Zoom would make the most sense.

518
00:37:29,980 --> 00:37:30,980
That would be fine with us, your honor.

519
00:37:30,980 --> 00:37:36,980
So are there any other matters that anyone wishes to raise? Mr. Sponder?

520
00:37:36,980 --> 00:37:50,980
Thank you, your honor. Just wanted to piggyback off of Mr. Stark's comments to customers and just set forth on the record also that if customers do receive correspondence requesting their personal information that they should reach out to the United States trustee's office.

521
00:37:50,980 --> 00:37:54,980
Great. Thank you. Appreciate that as well.

522
00:37:54,980 --> 00:37:58,980
Quick question on the sale motion.

523
00:37:58,980 --> 00:38:06,980
Can we give a short update? Are we going forward with the motion? I don't know what what transpired with the transaction.

524
00:38:06,980 --> 00:38:14,980
Yes, your honor. We do anticipate going forward with the motion. And to my knowledge, it will not be contested, but I don't believe the objection deadline has run.

525
00:38:14,980 --> 00:38:15,980
Okay.

526
00:38:15,980 --> 00:38:16,980
All right.

527
00:38:16,980 --> 00:38:20,980
Then we're good. I appreciate everybody's efforts.

528
00:38:20,980 --> 00:38:25,980
And reach out for chambers as the need arises. Otherwise, be safe. Take care.

529
00:38:25,980 --> 00:38:28,980
Thank you, your honor.

530
00:38:28,980 --> 00:38:31,980
And we're done.

531
00:38:31,980 --> 00:38:32,980
Good.

532
00:38:32,980 --> 00:39:00,980
Goodbye. Okay, great. Thank you. Thank you all.