George L. Miller, Trustee

Eight Penn Center, Suite 950

1628 John F. Kennedy Boulevard

Philadelphia, PA 19103

 

Phone: (215) 561-0950

Fax: (215) 561-0330

Email: gmiller@millercoffeytate.com

 

 

December 23, 2014

 

STATUS UPDATE # 36

 

NOTE: The Status Updates are cumulative. Please read all thirty-six updates.

 

Bankruptcy Court Action

 

     The only remaining Defendant in the Bankruptcy Court action is Greenwich Capital Financial Products, Inc. ("Greenwich"). The Trustee has a settlement in principal with Greenwich, subject to documenting the agreement, which the Trustee believe will be filed with the Bankruptcy Court by March 31, 2015.

 

Potential Tax Claim

 

       The Potential Tax Claim with the Internal Revenue Service will require the Trustee to file numerous tax returns and amend the tax returns for the prior ten years. The Trustee anticipates this procedure will quantify the maximum claim exposure to the Internal Revenue Service.

 

Consolidation

 

        The Trustee anticipates requesting the Bankruptcy Court to allow the consolidation of all Debtors to result in one creditor base. This request should be filed by April 30, 2015.

 

Interim Distribution

 

       The Trustee anticipates paying an Interim Distribution pursuant to the priorities of the Bankruptcy Code after the quantification of all liabilities and the case consolidation are determined. The Trustee estimates that all secured, Chapter 11 and priority claims will be paid in full and a pro rata distribution to General Unsecured Creditors may occur. No estimates on distributions to unsecured creditors can be determined at this time.