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Filing for Chapter 11 Bankruptcy in Los Angeles

How Our Los Angeles Bankruptcy Lawyers Can Help You

Chapter 11 bankruptcy is known as reorganization bankruptcy and is used by businesses, including small businesses, partnerships, sole proprietorships, and corporations, to reorganize their assets to save the business and pay off debts. A Chapter 11 debtor has the exclusive right to file a plan of reorganization with the bankruptcy court for 120 days under 11 U.S.C. § 1121(b) of the Bankruptcy Code. This period can be extended by the bankruptcy court but after it expires, creditors or trustees may file separate plans with competing interests.

The Los Angeles Chapter 11 bankruptcy lawyers at the Law Offices of Michael Jay Berger help debtors work out a plan of repayment for approval by a bankruptcy court judge. Filing a repayment plan makes debt more manageable for businesses because it stops creditors from pursuing collection actions and foreclosures, and it allows businesses to restructure their assets to continue operations successfully. We help clients through the entire bankruptcy process, which includes the following:

  • Filing a bankruptcy petition
    • Filing required bankruptcy documents, such as a statement of financial affairs
    • Drafting disclosure statements
    • Filing a plan of reorganization
    • Modifying reorganization plans
    • Filing necessary motions and fighting creditor motions
    • Representing clients in adversary proceedings
  • Filing a bankruptcy petition and bankruptcy schedules
    • Completing the 7 day package. This includes advising the debtor regarding the requirements of the Office of the United States Trustee as set forth in its Guidelines and Requirements for Chapter 11 Debtors in Possession.
    • Preparing Applications to Employ Professionals, including General Counsel and Real Estate Brokers.
    • First Day Motions, including Utilities Motions, Payroll Motions, Motions to Pay Essential Suppliers, Motion to Pay Health Care Providers
    • Preparing Cash Collateral Motions
    • Preparing Valuation Motions
    • Opposing Motions for Relief from Stay
    • Assisting the Debtor in Preparing Monthly Operating Reports.
    • Filing necessary motions and fighting creditor motions
    • Representing clients in adversary proceedings
    • Drafting and amending disclosure statements and plans of reorganization

The length of time it takes to develop and present a Chapter 11 plan of reorganization depends on the circumstances of the business and its debts, but typically takes several months. I will personally analyze business assets and debts to evaluate the length and complexity of your bankruptcy proceeding.

Pros and Cons of Chapter 11
Bankruptcy Basics, Key Terms and Parties

  • Document by Small Business Reorganization Task Force Final Report December 2020, United States Bankruptcy Court Central District of California. This Task Force was led by USBC Judges Maureen A. Tighe, Scott C. Clarkson and Neil W. Bason. 

Our experienced and successful Chapter 11 bankruptcy lawyers in Los Angeles include Sofya DavtyanCarolyn Afari, and Robert Poteete, who work under the guidance of firm founder Michael Jay Berger. Together, we help businesses restructure their operations through Chapter 11 and continue on to successful operations.

I have represented the debtor in more than 150 Chapter 11 cases. In these cases, my Associate Attorneys and I have successfully prepared many types of Applications and Motions, including, but not limited to, First Day Motions, Employment Applications, Fee Applications, Motions to Sell both real and personal property, and Valuation Motions. We have successfully opposed many kinds of Motions including, but not limited to, Motions for Relief from Stay, Motions to Allow a Receiver to Remain in Place, and Motions to Convert or Dismiss. We have done every type of OUST compliance, and represented debtors at Initial Debtor Interviews, 341(a) Hearings, 2004 exams, Status Conferences, Cash Collateral Motions and other Motion Hearings. We have had Disclosure Statements approved and confirmed Plans of Reorganization.

On January 26, 2024, Sofya Davtyan and I confirmed a plan of reorganization for jointly administrated Subchapter V Debtors, Phenomenon Marketing & Entertainment, LLC and Phe.no, LLC in the United States Bankruptcy Court, Central District of California, Bankruptcy Case Nos.: 2:22-bk-10132-BB and 2:22-bk-10715-BB. The Debtor Phenomenon Marketing & Entertainment, LLC is in the business of advertising and marketing. Joint Debtor, Phe.no, LLC is the sole member of the Debtor. Problems caused by Covid-19, Debtor’s reputation from previous management and Debtor’s unsuccessful negotiations with its landlord were the driving factors for Debtor’s financial problems and precipitated the bankruptcy filing. Immediately after the filing of the bankruptcy case, Sofya and I moved to reject the debtor’s lease to prevent the Debtor from incurring post-petition administrative rent expense for the duration of the case. We obtained an order from the Court approving a $1 Million post-petition financing to assist the Debtor with covering its operating expenses while it was navigating through the reorganization process. This case included a fight that we ultimately won regarding the debtor’s eligibility to be a Subchapter V debtor. Judge Ernest M. Robles issuing a Memorandum of Decision on April 28, 2022 sustaining the landlord’s objection to the debtor’s eligibility to proceed under Subchapter V of Chapter 11, but then, on August 1, 2023, Judge Robles granted our Motion to Reinstate Debtor’s Status as a Subchapter V Debtor. This proved critical to the success of the case as we were able to confirm the reorganization plan without any creditor votes approving the plan. On September 15, 2023, the cases were reassigned to Judge Sheri Bluebond. We helped the Debtor settle all of its disputes with its largest creditors. At the time of the filing, Debtors had $922,311.62 in secured debt and $11,386,588.19 in scheduled general unsecured debt, which consisted of delinquent rent, business loans, pending lawsuits, and legal fees. We proposed and confirmed a 5-year plan that pays the secured creditors over 5 years, reduced the general unsecured obligations from $11,386,588.19 to $2,908,679.18 and pays a 3% distribution to the general unsecured creditors over a 60-month period. The chapter 11 filing gave Debtors the ability to successfully restructure their business, reduce the overhead expenses and debts, and resolve all of their pending disputes.

On January 23, 2024, Sofya Davtyan and I confirmed a Subchapter V Plan of Reorganization for DVD Factory, Inc., Case No.: 2:23-bk-11085-DS in the United States Bankruptcy Court, Central District of California. The Debtor manufactures adult DVDs. It is the only remaining business in America that does this. The events that caused the filing of the case included a breach of contract judgment and a labor law class action lawsuit. The case was highly contested by three unsecured creditors. They filed objections to claims, a motion to remove the Debtor from possession, and objections to Debtor’s plan. Judge Saltzman held an evidentiary hearing on the feasibility of the Debtor’s proposed plan, and we prevailed for our client, aided by the brilliant testimony of DVD Factory, Inc.’s owner, Daniel J. Quinn. We confirmed Debtor’s plan of reorganization over the objections of these creditors. Debtor’s plan proposes a 5-year repayment plan to holders of allowed claims, without interest, while offering 0% distribution to the claimants of the labor law class action, whose claim was disallowed.

On December 7, 2023, Sofya Davtyan and I confirmed a consensual plan of reorganization for Subchapter V Debtor Cenports Commerce Inc. in the Northern District of California, Bankruptcy Case No.: 23-bk-40478-CN. The Debtor is a B2B drop shipping (virtual distribution) company that helps brands sell products online to Home Depot, Lowes, and other companies under their own accounts. At the time of the filing, Cenports had $1,989,813.00 in scheduled secured debt and $5,057,890.00 in scheduled general unsecured debt, which consisted of trade debt, credit cards, merchant cash advance loans, vendors, and pending lawsuits. Sofya and I were able to reach plan treatment stipulations with Debtor’s creditors, including the Small Business Administration (SBA) and ARC Technology. We proposed and confirmed a 5-year plan that reduced the secured debt from $1,989,813.00 to $272,707.00 to be paid over 5 years and treated the balance of the undersecured obligations, consisting mostly of merchant cash advance loans secured by UCC-1 Financing Statements, as general unsecured claims. The plan pays 1% of $6,211,806.26 total general unsecured claims at $1,035.30 per month for 60 months. The chapter 11 filing gave Debtor the ability to successfully restructure its business model, reduce its overhead expenses and debts, favorably resolve claims, and generate the income needed to support the payments proposed under the plan. The Debtor’s principal is very happy with the results. Sofya and I take pride in helping small and medium size businesses reorganize and greatly reduce their debts. Chapter 11 can be an excellent tool for dealing with onerous merchant cash advance loans. We can help you reorganize your business as well. For more information and to schedule a free consultation, please contact our office.

On October 25, 2023, Sofya Davtyan and I confirmed a Subchapter V Plan of Reorganization for Robert Lee Alderman and Noni Elizabeth Alderman, Case No.: 1:22-bk-11170-VK. At the time of the filing, the Debtors owned two rental properties (Brunswick and Valley View rental properties) and their principal residence. The bankruptcy was filed to stop the pending foreclosure sale for the Brunswick rental. The lenders for the Brunswick rental and the principal residence both filed motions for relief from the automatic stay to foreclose on the properties. Sofya and I negotiated plan treatment stipulations with these lenders, which resolved the relief from stay motions, modified debtor’s loans and provided for cure of the pre-petition arrears over time. We also successfully filed a sale motion for the Valley View rental. Our clients, Sofya and I are all extremely pleased with the results achieved for these Debtors.

On August 30, 2023, Sofya Davtyan and I confirmed a Subchapter V Plan of Reorganization for Vici Wellness, Inc., Case No.: 8:23-bk-10612-TA in the United States Bankruptcy Court, Central District of California, Santa Ana Division. Vici Wellness, Inc. is in the business of selling wellness products on its website, including wellness patches, oils, lotions, candles, matches, sleep masks, and other similar products.  The Debtor obtained a number of hard money loans guaranteed by its principals, but due to high payments, was not able to keep up with the monthly obligations.  This was the main reason for the bankruptcy filing.  To solve this problem, we entered into plan treatment stipulations with American Express, On Deck Capital, and The Business Backer for repayment of the loans over 60 months at no interest with an agreement that these creditors will not pursue any action against the guarantors during the 60-month repayment term.  The principals of the Debtor retained their interests in the Debtor. The Debtor is now financially stable and is able to afford the greatly reduced payments proposed under the Plan.  Vici’s plan was confirmed as a consensual plan pursuant to 11 U.S.C. Section 1191(a).  In a consensual plan, the Subchapter V Trustee’s services are terminated upon substantial consummation of the plan.  This is commonly interpreted to mean that the Subchapter V Trustee’s services end when payments to creditors begin.  This saves money for the debtor.  Our total legal fees and costs for filing this Subchapter V Chapter 11 case and successfully prosecuting it through plan confirmation were less than $24,000.00.

On August 30, 2023, Sofya Davtyan and I confirmed a Subchapter V Plan of Reorganization for Surrender Solutions, Inc., Case No.: 8:23-bk-10612-TA. This Debtor is related to Vici Wellness, Inc. The Judge for both this Chapter 11 and the related Vici Wellness, Inc. Chapter 11 is Theodore C. Albert. Vici Wellness, Inc., this debtor is in the business of selling wellness products, but it sells its products on Amazon.  The main reasons for filing this bankruptcy case were the high monthly obligations on the business loans and the insufficient cash flow to satisfy these payments.  We reached adequate protection and plan treatment stipulations with the SBA and Amazon Capital Services.. Debtor’s plan calls for repayment to the creditors over 60-months, with payments that the Debtor can afford.   Surrender Solutions’ plan was confirmed under 11 U.S.C. Section 1191(a) as a consensual plan. Our total legal fees and costs for filing this Subchapter V Chapter 11 case and successfully prosecuting it through plan confirmation were $25,234.00.

On August 30, 2023, Sofya Davtyan and I confirmed a Subchapter V Plan of Reorganization for Yitbos Inc. dba Mr. Pickles Sandwich Shops, Case No.: 2:23-bk-20913 in the Eastern District of California, Sacramento Division,  This case was assigned to Judge Christopher M. Klein. The Debtor was formed in 2015, and since then it acquired and operated five Mr. Pickles sandwich shops.  Due to a shortfall in income,  Debtor was forced to obtain hard money loans and fell behind on the payments. This is a common problem for many of our Chapter 11 clients.  At the time of the filing, the Debtor also owed over $264,643 to California Department of Tax and Fee Administration (“CDTFA”).  Through the reorganization plan, we helped the Debtor save its 5 sandwich shops, assume the lease agreements and executory contracts, and enter into a 5-year repayment plan to CDTFA and to general unsecured creditors.   The hard money lenders are being repaid their principal without any interest, and all threatened lawsuits were avoided. Debtor’s principal retained 100% of his equity interest in Yitbos Inc.  We were able to obtain votes from all impaired classes in favor of Debtor’s plan.  In less than six months, we successfully managed this case from filing through a confirmed consensual plan. Our total legal fees and costs for filing this Chapter 11 case and successfully prosecuting it through plan confirmation were less than $50,000.00.

On July 19, 2023, my partner Sofya Davtyan and I confirmed a plan of reorganization in a Subchapter V Chapter 11 case entitled In re Unified Security Services, Inc, Case No.: 2:21-bk-18392-NB. The case was initially filed as a regular chapter 11 case, but subsequently converted to subchapter V. The Debtor filed this Chapter 11 bankruptcy due to pending state court lawsuits against it, including a $4.5 Million wage and hour class action lawsuit and a pending wrongful termination lawsuit. Sofya and I facilitated a mediation with Debtor’s largest creditor holding the $4.5 Million dollar claim, reached a global settlement at the mediation, and obtained the creditor’s vote in favor of Debtor’s plan confirmation. As a result of our efforts, the Debtor is finally able to end the lengthy and expensive state court action and resolve the litigation which has been pending against it and other non-debtor defendants since 2012. The plan allows the Debtor to settle its remaining general unsecured debt totaling $320,031.55 by paying 1 cent on the dollar (1% over 5 years!) while paying the priority taxes owed to the California Department of Tax and Fee Administration, the Internal Revenue Service, and Employment Development Department over 5 years from the petition date. Another great success story for our client!

Sofya and I helped many small business owners resolve employment related claims both by filing for chapter 11 bankruptcy and by negotiating with counsel representing the labor law claimants. We are ready to help you solve your financial problems. Call us at (310) 271-6223 for a free consultation.

On March 10, 2023, Sofya Davtyan and I confirmed a Subchapter V Plan of Reorganization in a Chapter 11 case entitled In re Landmark 99 Enterprises, Inc. dba Wilma & Frieda’s, Case No.: 1:22-bk-10148-VK. The Debtor operates a restaurant in Palm Springs. The Subchapter V Plan reduces Debtor’s secured obligations from $581,596.00 to $60,000 to be paid over 60 months at $1,000 per month and allows the Debtor to settle its general unsecured debt of approximately $546,647.42 by paying 5 cents on the dollar (5% over 5 years!). The plan proposes to cure the priority tax obligations owed to the IRS, California Department of Tax and Fees, and Employment Development Department over a 5-year period and resolve the IRS’ post-petition administrative claim by making a payment on the effective date. The Debtor filed this Chapter 11 bankruptcy due to its delinquent lease obligations and its substantial tax liability. We were able to enter into plan treatment stipulations with the landlord and the IRS. Landmark was able to save its restaurant, avoid unlawful detainer proceedings, enter into agreements with taxing authorities, favorably resolve all of the claims against it, continue the operation of its business and focus on new projects to increase the revenue through catering, special events, and other seasonal events. This case is an affiliate of Wilma and Frieda, which we confirmed four months ago. The principals of both Debtors are extremely pleased with the quality of our work, our timeliness in confirming both plans, and the reasonableness of our fees. We have represented many restaurants. We can help you reorganize your business. For more information and to schedule a free consultation, please contact our office.

On February 22, 2023, my hard-working partner Sofya Davtyan and I confirmed a chapter 11 plan of reorganization for another solar energy company, Energy Enterprises USA Inc. dba Canopy Energy, Case No.: 1:21-bk-11374-MT. The Debtor, also referred to as EEUSA, has been providing solar panel installation services since 2016. EEUSA had $8,747,625.00 in scheduled unsecured debt, including employment labor law claims, workers’ compensation claims, breach of contract lawsuits, unpaid vendor invoices, and hard money loans. In addition, EEUSA owed $417,111.00 in priority tax debt to the Internal Revenue Service, the Employment Development Department, the California Department of Tax and Fees, the City of Los Angeles Finance Department, and the Franchise Tax Board. EEUSA had secured debt of $167,395.94 which included an EIDL SBA loan, an EDD tax lien, and a judgment lien. On March 17, 2023 the Court entered its Order of Discharge – Chapter 11 in this case.

Sofya and I were able to reach plan treatment stipulations with the EDD, the IRS, the City of Los Angeles and the secured judgment creditor. We proposed and confirmed a 5-year repayment plan for priority taxes, and discharged $8,747,625.00 in scheduled unsecured debt by paying a 1% distribution to allowed general unsecured creditors at $533.73 per month for 60 months. We were also successful in objecting to a number of claims and entered into stipulations with other creditors to greatly reduce the amount of their claims. The chapter 11 filing gave Debtor the breathing spell that it needed to restructure its business, reduce its overhead expenses, reduce its legal fees, favorably resolve the claims brought by third parties against some of its officers and generate the income needed to support its plan payments. Debtor is thrilled with the results. Another successful confirmed chapter 11 plan!

On February 1, 2023, my Partner Sofya Davtyan and I confirmed a Chapter 11 Reorganization Plan in the United States Bankruptcy Court, Southern District of California, for Monica L. Coleman, Case No.: 21-04069-MM11. Prior to the filing, the Debtor had been unsuccessfully attempting to negotiate a loan repayment plan with her secured creditor, Hany Elwany, Trustee of the Hany Elwany Trust (“Elwany”). Debtor was unable to reach an agreement on the payoff amount, with a difference of more than a million dollars between the claimed amount and the amount that debtor believed was correct. Elwany recorded a Notice of Default and a Sale Notice for the Debtor’s Alpine property. We filed the chapter 11 bankruptcy for the Debtor in October 2021 to stop Elwany’s foreclosure sale and get Monica Coleman the time that she needed to sell or refinance her property. We proposed and secured Court approval for a very low monthly adequate protection payment to Elwany, and have already given the Debtor 16 months to market the Alpine property. The property is now in escrow, and the Court has given the Debtor several more months to complete a sale. We filed an adversary proceeding against Elwany to determine the actual amount of his claim. Our confirmed Chapter 11 Plan allows Debtor to sell the Alpine property free and clear of Elwany’s lien, with part of the sale proceeds being held in reserve pending the resolution of the adversary proceeding against Elwany.

On December 23, 2022, my amazing law partner Sofya Davtyan and I confirmed a Subchapter V Plan of Reorganization for El Calamar, Inc., Case No.: 8:22-bk-11188-TA. El Calamar, Inc. has operated a family-owned Mexican grill and seafood restaurant in Santa Ana since 2007. The event that triggered the bankruptcy filing was the action by judgment creditor Wesco Insurance Company to sell the Debtor’s liquor license to satisfy the obligation owed by the Debtor to Wesco. Sofya and I stopped the sale by filing Chapter 11 for the debtor. Then we entered into plan treatment stipulations with all of the Debtor’s secured creditors (Funding Circle, OnDeck Capital, SBA, and Wesco). We proposed and confirmed a 5-year repayment plan to priority creditors holding tax claims, with a 5% pro-rata distribution to holders of general unsecured claims totaling $159,342.49. Unsecured creditors will share $132.79 in monthly plan payments for 5 years. The Debtor’s principal will retain 100% of his equity ownership interest in El Calamar, Inc. The plan treatment stipulation with Wesco bifurcated Wesco’s $135,205.65 claim into a $25,000.00 secured claim to be paid over 5 years at $416.66/month and treated the $110,205.65 balance as a general unsecured claim.The case was filed in July 2022 and within 6 months, we helped El Calamar successfully confirm a consensual Subchapter V Plan. Our client, Sofya and I are all delighted with the results.

On December 13, 2022, my wonderful law partner Sofya Davtyan and I confirmed a Plan of Reorganization for Larry J. Cummings, Case No.: 6:20-bk-14708-SY. Cummings used to operate two restaurants called The Grill, one located in Twin Peaks and one in Lake Arrowhead Village. The major event that precipitated the filing of the chapter 11 bankruptcy for the Debtor was the closure of his restaurants due to Covid-19 and the tax liability Debtor had incurred during the time he was ill and unable to manage the restaurants. Sofya and I were able to reject the lease for the Lake Arrowhead location. At the time of the rejection, Debtor had accumulated a post-petition administrative claim in favor of the Lake Arrowhead Landlord for $103,177.76 and a general claim for $341,021.98 representing the unpaid $137,010.26 pre-petition rent and the estimated $204,011.72 in post-petition damages under the Lake Arrowhead Lease. Sofya and I were able to enter into a plan treatment stipulation with Lake Arrowhead Landlord pursuant to which the entire claim was deemed satisfied in full upon allowing the Landlord to retain the $7,500 deposit and total payments by the Debtor of $12,500 to the Landlord in ten monthly installments of $1,250.00 each. Sofya and I were also successful in entering into plan treatment stipulations with the Internal Revenue Service and California Department of Tax and Fees. We proposed a successful reorganization plan which pays Debtor’s general unsecured creditors with claims totaling $659,165.08 (including Lake Arrowhead Landlord’s general unsecured balance) a 2% distribution over 5 years. Our client, Sofya and I are all extremely pleased with the results achieved for this Debtor. We can help you to successfully reorganize your business as well. All you need to do is give us a call for a free consultation.

On November 23, 2022, my transcendently beautiful and talented partner Sofya Davtyan and I confirmed a Subchapter V Plan of Reorganization in a Chapter 11 case entitled In re Wilma & Frieda Inc dba Wilma & Frieda’s Cafe, Case No.: 1:22-bk-10147-VK. The Debtor operates a restaurant in the Palm Desert area. The plan reduces Debtor’s secured obligations from $640,000 to $60,000 to be paid over 60 months at $1,000 per month and allows the Debtor to settle its general unsecured debt totaling approximately $670,000 by paying 2 cents on the dollar (2% over 5 years)! The plan also proposes to cure the pre-petition tax obligations owed to the IRS, California Department of Tax and Fees, and Employment Development Department over a 5-year period. The Debtor filed this Chapter 11 bankruptcy due to a pending notice of judgment lien, delinquent lease obligations, and substantial tax liability. We were able to enter into plan treatment stipulations with the landlord, and the IRS, and we recovered all of the levied funds back from Square. By hiring us and filing Chapter 11 bankruptcy, Wilma & Frieda was able to save its restaurant operation, avoid eviction, enter into favorable agreements with taxing authorities. We resolved all of the claims against it and continued the operation of its business without any interruption. This is an amazing result for our client! Today we received a beautiful box of cookies and cakes from our client as another thank you for our successful efforts. We have helped many restaurants. We can help you reorganize your business. For more information and to schedule a free consultation, please contact our office.

On November 14, 2022, my incomparable, irreplaceable Partner Sofya Davtyan and I confirmed a consensual Subchapter V Plan of Reorganization for BMW, Nationwide Security, Inc, Case No.: 2:22-bk-12988. The events that precipitated the bankruptcy filing were the pending lawsuits against the Debtor for labor law/discrimination by creditor Delores Ward, and the indemnification claim by Goldenvoice, LLC and the Al Malaikh Auditorium based on a personal injury claim made by Edna Herrarte-Giron. Debtor also had a Paycheck Protection Program loan for $500,000, which was not yet forgiven as of the petition date. We were able to enter into a Stipulation re Relief from the Automatic Stay whereby Goldenvoice, LLC and the Al Malaikh Auditorium only pursued the applicable insurance and recovered $0 from the Debtor. We proposed and confirmed a Subchapter V Plan of Reorganization which pays $0.00 to disputed creditor Delores Ward for her alleged discrimination/labor law claims. We reached an agreement with the SBA regarding the debtor’s PPP Loan, pursuant to which the Debtor will be able to resubmit its forgiveness application, and, if all or part of $500,000 PPP loan is not forgiven, the Debtor will only have to pay $12,218.29 in 12 installments of $1,018.19 each. By filing and confirming the Subchapter V Plan, we favorably resolved the debtor’s pending lawsuits and saved Debtor hundreds of thousands of dollars in debts and legal fees for defending these lawsuits in state court. We have helped many security guard companies to file and confirm Chapter 11 plans. We are familiar with all types of labor law claims that are typically filed against security guard companies, and we are skilled in successfully and economically dealing with them.

On September 2, 2022, my beautiful and brilliant Partner Sofya Davtyan and I confirmed a consensual Subchapter V Plan of Reorganization pursuant to 11 U.S.C. Section 1191(a) in the United States Bankruptcy Court, Eastern District of California, Fresno Division, In re California Roofs and Solar, Inc., Case No.: 1:22-bk-10061. At the time of the filing of this case, Debtor’s contractor’s license was revoked due to an unpaid construction related civil judgment, as a result of which Debtor was not able to accept any jobs. Northern California Collection Services Inc. had obtained a $456,618.29 judgment against the debtor based on a State Fund workers compensation audit. Our Chapter 11 filing enabled the debtor to get its license put back into active good standing. Debtor was then able to accept new projects and get the income that it needed to support a feasible reorganization plan.

We have helped many construction companies with unpaid construction related judgments to get their license put back into good standing by filing Chapter 11. Several of these companies had judgments related to State Compensation Insurance Fund Workers Compensation Insurance audits. Some had default judgments against them, and were also facing levies on their bank accounts.

Through Debtor’s Subchapter V Plan, Debtor is paying Employment Development Department’s priority tax obligation over 5 years from the petition date. Sofya and I were able to reach a plan treatment stipulation with Northern California Collection Services Inc., pursuant to which NCCS’s claim was bifurcated into a $16,188.95 secured claim to be paid over 5 years at $343.97 per month and treat the $443,429.34 balance as a general unsecured creditor. The Debtor discharged $556,446.68 in general unsecured debt by paying a 2% dividend over 5 years at $185.48 per month. Debtor’s principal, Carlos Colima, and its other shareholders all retained their interests in the Debtor.

Also On September 2, 2022, my brown-eyed, compassionate and charming Partner Sofya Davtyan and I achieved a consensual plan confirmation under 11 U.S.C. Section 1191(a) for a Chapter 11 Subchapter V Plan of Reorganization in In re Cico Electrical Contractors, Inc., Case No.: 2:22-bk-19348-VZ. This case was filed in the United States Bankruptcy Court, Central District of California. The Debtor was formed in 2004. It specializes in building and maintaining electrical infrastructures for various facilities, including installation of electrical systems (low, medium, and high voltage) and emergency stand-by generation equipment, doing work for health care facilities (OSHPD) and for public works MEP facilities. Debtor also offers temporary power solutions, industrial controls, testing and preventative maintenance. Debtor’s customers include counties and city governments, hospitals, and large private entities such as Disney, ABC, among others. Debtor typically acts as a subcontractor on various large projects but also performs work directly for customers, such as Kaiser Foundation, Riverside County, Veterans Administration, and Disney.

The filing of the bankruptcy was caused by the aftermath of Covid-19 pandemic, which affected the Debtor’s ability to collect the receivables from its clients, and by a number of lawsuits and judgments obtained against the Debtor. This was not an easy case.

Sofya and I were able to reach several plan treatment stipulations with Debtor’s largest creditors to achieve a consensual plan confirmation. Sofya and I reached a global settlement agreement with Debtor’s largest secured creditor, American Contractors Indemnity Company (“ACIC”) which had a Notice of Judgment Lien filed with the Secretary of State for $983,991.25 and was aggressively pursuing collection against the Debtor and its principals. We also reached a plan treatment stipulation with the Inland Empire IBEW-NECA Defined Contribution Trust Plan for payment of priority and administrative claims through Debtor’s Sub V Plan. IBEW-NECA Trust also had a Notice of Judgment Lien filed with the Secretary of State and was intercepting payments which in turn was affecting Debtor’s ability to continue operating its business. We entered into another plan treatment stipulation with National Electrical Benefit and National Electrical Annuity Plan. We also reached plan treatment stipulations with the Internal Revenue Service and Employment Development Department. The Debtor discharged $1,116,158.24 in general unsecured debt by paying a 2% dividend over 5 years at $309.49 per month. Debtor’s case was highly contested by numerous creditors. However, with the intelligence, experience and knowledge that Sofya and I have as certified specialists in bankruptcy law and our extensive experience confirming Chapter 11 plans, we were able to confirm a consensual plan in less than ten months from the December 21, 2021 filing date. Outstanding results! Very happy client!

We have helped many construction companies with union problems, bond problems and tax problems. Sofya and I confirmed 2 plans in 2 different districts in California in one day! We are the Chapter 11 leaders!

On August 15, 2022, my Partner Sofya Davtyan and I confirmed a Subchapter V Plan of Reorganization in a Chapter 11 case entitled In re K. Anthony Incorporated dba K. Anthony Pre-School Inc., Case No.: 2:22-bk-10852-SK. K. Anthony School was established in 1982 and offers education to students in kindergarten, pre-school, and elementary schools in Inglewood, California. The filing was primarily driven by the substantial tax liability owed by the Debtor to the IRS ($967,636.14) and the Employment Development Department ($189,073.25), and the tax garnishments Debtor faced for years. Through Debtor’s confirmed Subchapter V Plan, the Debtor is paying $304,701.28 to the IRS and discharging the $662,934.86 balance by offering a 2% pro-rata distribution over 60 months. Through Debtor’s Subchapter V Plan, the EDD’s claim is being reduced to $79,178.64 to be paid over 5 years from the petition date, and the balance of $109,894.61 is to be discharged by paying a 2% pro-rata distribution over 60 months. It took us only six months from the filing date of February 16, 2022 to reach a consensual plan confirmation pursuant to 11 U.S.C. Section 1191(a), with a plan treatment stipulation reached with the debtor’s largest creditor, the IRS. K. Anthony’s owner and its officers are thrilled with the results that we obtained for them in this case. Sofya and I are very happy to be able to save this school which has been providing quality education to low-income students in the Inglewood community since 1982.

On July 18, 2022, my partner Sofya Davtyan and I confirmed a Subchapter V Plan of Reorganization in a Chapter 11 case entitled In re Amphil Group, LLC, Case No.: 2:21-bk-18014-VZ. Amphil’s secured creditor, SSA NE Assets, LLC was charging it a 45% default interest rate and attempting to foreclose on Amphil’s multi-million-dollar single family residence located in Walnut, California. We filed Chapter 11 for Amphil and stopped the foreclosure sale on Amphil’s property. During the Chapter 11, Sofya and I filed a Motion for Order Approving the Sale of the Property, filed an adversary proceeding against SSA, filed an objection to SSA’s claim, and negotiated a settlement with SSA, resolving the adversary proceeding and the claims objection. We reduced the default interest rate from 45% to 24%, won SSA’s vote in support of Amphil’s Subchapter V Plan, and obtained a stipulation that allows Debtor sufficient time to sell the Walnut property. Another great result achieved for our client! We are the Chapter 11 leaders!

On April 26, 2022, my Senior Associate Attorney Sofya Davtyan and I confirmed a Plan of Reorganization in a Chapter 11 case entitled In re DLR Express, Inc., Case No.: 6:20-bk-15258-SY. DLR is a trucking company offering both local and interstate transport of freight in California, Nevada, Arizona, Colorado, and New Mexico. The filing of the case was driven by a $6,094,702.00 default judgment obtained by Creditor Ronald E. Foster, Jr. against DLR arising from a state court personal injury lawsuit. DLR had an additional $612,855.00 in general unsecured debt which included various vendors, paycheck protection loan, and lines of credit. Debtor’s secured creditors included obligations secured by Debtor’s trucks and trailers with an estimated total claim amount of $1,980,673. At the time of filing, the debtor believed that it did not have insurance coverage that would cover the default judgment claim. DLR had already tried and failed to set aside the default judgment prior to hiring my firm, and it was at imminent risk of having its bank accounts levied and all of its assets taken from it. We got the insurance carrier to cover the claim, had the judgment reduced from $6,000,000.00+ to $1,000,000.00, got the insurance carrier to pay the $1,0000.000 and completely settled the claim at no cost to the debtor! We prevented an aggressive creditor / competitor from taking a Rule 2004 Examination, stopped an attempted hostile takeover of the company, and confirmed a consensual plan of reorganization for DLR. The DLR Chapter 11 case is another great success for our firm and for our client.

On March 30, 2022, I confirmed a plan of reorganization in a SubChapter V Chapter 11 Case entitled In re BCT Deals, Inc., Case No. 2:21-bk-18156-ER. The Plan allows the Debtor to pay twelve cents on the dollar to its general unsecured creditors over 5 years. Prior to the bankruptcy filing, the Debtor was embroiled in eight (8) lawsuits with some plaintiffs/creditors having obtained writs of attachment against the Debtor. The bankruptcy filing put an end to all litigation against the Debtor. It gave the Debtor the breathing room it needed to settle with its major creditors and reorganize its operations. Sam was able to negotiate settlements with two of Debtor’s secured creditors, PayPal/Swift Bank and FC Marketplace, LLC, and its largest unsecured creditor Eastern Unlimited, Inc. dba Fun World. These settlements resulted in overwhelming support for the Plan from Debtor’s creditors. Unsecured creditors holding 83.33% of claims in number voted to accept the Plan, and 89.14% of claims in amount voted to accept the Plan as well. The Plan was confirmed as a consensual Plan, which allowed the Debtor to receive its Discharge immediately rather than having to wait to substantially consummate the terms of the Plan first. Along the way, we were able to also find a new warehouse for the Debtor that significantly reduced its monthly rent from $25,000.00 per month to only $8,000.00 per month. Sam and I achieved an excellent result for our client within just five (5) months from the petition date!

On December 28, 2021, my Senior Associate Attorney Sofya Davtyan and I confirmed a Chapter 11 Plan of Reorganization in a Chapter 11 case entitled In re Anait Akopyan, Case No.: 1:19-bk-11192-MB. Debtor owns two rental properties (the Catalina Rental and Kingswell Rental), for which no payments were made for over 5 years. This case was filed to stop the foreclosure sale for the Catalina Rental. Both rental properties are secured by deeds of trust in first and second position and multiple judgment liens. The total amount for the judgment liens is $1,077,108.00. Nationstar Mortgage (1st TD Holder for the Catalina Rental) filed a claim for $2,176,575.94, asserting $731,753.55 in pre-petition arrears. We entered into a plan treatment stipulation with Nationstar Mortgage whereby the pre-petition arrears were added to the principal balance of the loan and the loan was re-amortized over a forty-year period. Real Time Resolution (“RTR”) (holder of the 2nd Td on the Catalina Rental) filed a claim for $1,386,115.47. We were able to enter into a plan treatment stipulation with RTR to treat $23,424.06 as a secured claim to be paid over 60 months from the Effective Date, and treat the $1,362,691.41 balance as a general unsecured claim (0% distribution). Nationstar Mortgage (1st TD Holder for the Kingswell Rental) filed a claim for $1,145,162.50, asserting $117,725.18 in pre-petition arrears. Debtor’s confirmed plan proposes to pay the pre-petition arrears over 60 months from the Effective Date. Real Time Resolution (2nd TD holder for the Kingswell Rental) filed a claim for $456,165.68. Pursuant to a claim treatment stipulation we reached with RTR, the $456,165.68 is considered a general unsecured claim and is receiving 0% through Debtor’s confirmed plan. The judgement liens totaling $1,077,108.00 were all successfully avoided from both the Kingswell and Catalina rentals and holders of these judgment liens are receiving 0% through Debtor’s confirmed plan. Sofya and I were also able to successfully resolve the two adversary proceedings filed against the Debtor by WFG Insurance and Novastar, which also resolved the underlying state court litigations that were pending for over 6 years. Sofya and I are thrilled with the results we got for the Debtor by discharging $2,919,470.22 in debt at 0% distribution to holders of these claims, and successfully renegotiating the loan terms for both rental properties and resolving the adversary proceedings. We both take pride in helping our clients get a fresh start.

On December 21, 2021, my Senior Associate Attorney Sofya Davtyan and I confirmed a Subchapter V Plan of Reorganization in a Chapter 11 case entitled In re Pacific Environmental Technologies, Inc., Case No.: 2:21-bk-16058-DS. Pacific Environmental Technologies, Inc. (“PETI”) has been in business since 1989 and offers modular, soft wall, mobile, and conventional cleanrooms, as well as refrigerated storages, freezers, and solar and energy storages to pharmaceutical, aerospace, and industrial companies. At the time of the filing, PETI had approximately $317,642.55 in secured debt, $253,602.84 in priority unsecured debt, and $1,813,556.93 in general unsecured debt, which included lawsuits for Breach of Contract, Open Book Account, a Contractors State License Board complaint, and a pending Unlawful Detainer case. Sofya and I stayed the lawsuits, entered into a plan treatment stipulation with the landlord, resolving the pending unlawful detainer action and allowing the Debtor to successfully assume the lease. The confirmed Sub V Plan reduced PETI’s secured obligations from $317,642.55 to $265,751.82 by proposing to pay $3,164.97 per month for 60 months, set up a payment arrangement for Debtor to satisfy its $236,159.95 priority tax obligations by making monthly payments over 60 months from the petition date, and discharged $1,813,556.93 by offering a 10% distribution to the allowed general unsecured creditors ($1,656,590.74) over 5 years at $2,783.24/month. We are the chapter 11 leaders in Southern California! We take pride in helping small business owners get a fresh start.

On June 29, 2021, my Senior Associate Attorney Sofya Davtyan and I confirmed a Subchapter V Plan of Reorganization in a Chapter 11 case entitled In re RedRhino: The Epoxy Flooring Company Inc., Case No.: 2:20-bk-20257-SK. RedRhino is in the business of providing protective coating, overlaying, and polished concrete services to the industrial and commercial work spaces. At the time of the filing, RedRhino had approximately $782,275 in secured debt and approximately $781,174 in general unsecured debt, which included several confessions of judgments obtained against RedRhino. The confirmed Sub V Plan reduced RedRhino’s secured obligation from $782,275 to $75,926.87 by proposing to pay $1,265.45 per month for 60 months, and discharged $1,542,086.85 by offering a 1% distribution to the allowed general unsecured creditors over 5 years at $336.70 per month! Sofya and I achieved an excellent result for our client within just 7 months from the petition date!

On June 10, 2021, my Senior Associate Attorney Sofya Davtyan and I confirmed a plan of reorganization in a Chapter 11 case entitled In re Talk Venture Group, Inc., Case No.: 8:19-bk-14893-TA. Talk Venture Group is in the business of selling various merchandise on Amazon.com. The event precipitating the filing of Talk Venture’s chapter 11 bankruptcy was the UCC Lien Notice sent by Pearl Beta Funding, LLC to Amazon’s Legal Department requesting Amazon to divert Talk Venture’s receivables to Pearl Beta Funding, LLC to satisfy the outstanding obligation. Talk Venture Group’s secured liabilities consisted of 10 business loans with the creditors holding UCC Financing Statements for an estimated $4.3 Million and monthly payments on these obligations totaling $140,594 per month! Talk Venture also had an estimated $1.8 Million in general unsecured claims. The confirmed plan reduced Talk Venture’s secured obligation from $4.3 Million to $1,297,990.91, reduced the monthly payments on the secured obligations from $140,594/month to $16,743/month, and discharged $4,109,885 by offering a 1.1% distribution to these creditors over 5 years at $757.04 per month! Holders of the top 4 senior secured claims (Wells Fargo Bank and Banc of California) vigorously objecting to Debtor’s Plan and unsuccessfully opposed almost everything that we did in this case. Sofya and I were able to resolve Wells Fargo’s and Banc of California’s objections and gain their votes in favor of Debtor’s Plan. Another excellent result obtained for our client by the only two Beverly Hills Certified Bankruptcy Law Specialists!

On June 10, 2021, my Senior Associate Attorney Sofya Davtyan and I confirmed a plan of reorganization in a Chapter 11 case entitled In re Paul Se Won Kim, Case No.: 8:20-bk-10168-TA. This case is related to Talk Venture Group, as Mr. Kim is the principal and owner of Talk Venture Group. The catalyst for Mr. Kim’s personal chapter 11 bankruptcy was the decline in Talk Venture’s business revenue, which made it difficult for Mr. Kim to stay current with all her personal obligations, and the business debts that he had personally guaranteed. Due to the decline in Mr. Kim’s income, at the time of the filing, he was delinquent on his mortgage payments to Union Bank (holder of both the 1st and 2nd loans), had an unpaid property tax bill for $63,243, tax liability of approximately $58,582, and general unsecured obligations totaling approximately $6,160,229.58. The confirmed plan gives Mr. Kim 5-years to pay the pre-petition mortgage arrears owed to Union Bank and the delinquent property taxes. The plan reduces Mr. Kim’s general unsecured liability from $6,160,229.58 to $3,694,862.75 and pays holders of these allowed general unsecured claim 1% over 5 years at $615.79 per month! Sofya and I take pride in achieving stellar results for our clients, and Mr. Kim’s Chapter 11 is another example of what we do for our clients at the Law Offices of Michael Jay Berger. Judge Albert personally congratulated us both on confirming these 2 Chapter 11 plans!

On May 21, 2021, my Superstar Senior Associate Attorney Sofya Davtyan and I confirmed a plan of reorganization for a non-profit organization in a Subchapter V Chapter 11 case entitled In re Real Estate Recovery Mission, Case No. 2:20-bk-19134-VZ. The catalyst for the filing of the case was a pending foreclosure sale for one of the Debtor’s six properties, which provide safe and affordable housing to low-income veterans and homeless people in Riverside county. We stopped the foreclosure sale for this property, got the debtor the time that it needed to rehab 2 of the properties, assisted the Debtor with the sale of three of its other real properties by successfully filing sale motions, settled the adversary proceeding complaint filed against the Debtor for Declaratory Judgment, and proposed and confirmed a five-year repayment plan to Debtor’s general unsecured creditors at $183.34/month. The sales of the properties generated money to help the homeless. By filing the Chapter 11 bankruptcy and confirming the Subchapter V Plan, the Debtor was able to avoid losing the equity in its properties and continue its charitable mission.

On May 12, 2021, I confirmed a plan of reorganization in a Subchapter V Chapter 11 Case entitled In re Nuance Energy Group, Inc., Case No. 2:20-bk-17761-VZ. The plan allows the Debtor to pay sixteen cents on the dollar to its general unsecured creditors over 5 years, wipes out over $3 million dollars of debt, and makes the debtor’s principal its sole shareholder. We overcame the objection of one of the debtor’s largest creditors and put an end to all litigation against the debtor. Along the way, we successfully objected to numerous creditor’s claims and entered into stipulations with other creditors regarding their claims. We strategically used several of the unique features of Subchapter V to confirm a plan that could only be confirmed as a Subchapter V Plan. This includes the elimination of the “consenting class” requirement and the “absolute priority rule.” We convinced the Subchapter V Trustee Greg Jones to support approval of our plan.

On December 18, 2020, I confirmed a plan of reorganization in a Chapter 11 case entitled In re Marco General Construction, Inc., Case No.: 2:19-bk-14758-BB. The catalyst for the filing of this case was a $416,506.49 default judgment against the debtor from a workers’ compensation insurance audit. When the client contacted me for the first time, its bank account had already been levied on and it was completely out of money. I filed Chapter 11 for the client, thereby triggering the automatic stay. When the debtor’s bank refused to promptly release the debtor’s funds to the debtor and creditor’s counsel refused to cooperate with us, I filed and won a Motion for Turnover of Property of the Debtor. The Court ordered the bank to release its levy on the debtor’s account and return 100% of the levied funds to the debtor. I sought and obtained relief from stay from the Bankruptcy Court to file a Motion to Set Aside Default and Default Judgment in the State Court case. Then Sam and I prepared, filed and won a Motion to Set Aside the Default and Default Judgment. A secondary factor in the filing of the Chapter 11 case was a Florida lawsuit against the debtor for $100,000+ based on the debtor’s liability for a hard money loan that was secured by all of debtor’s receivables. Sam worked out Plan Treatment Stipulations with 2 of the debtor’s secured, hard money lenders, Kalamata Capital Group and 1 West Capital, LLC. This created an impaired class that consented to our plan of reorganization, giving us what we needed to confirm our plan. Then, by getting a vote from American Express in favor of our proposed plan, we won approval from the general unsecured class of creditors too! The confirmed plan includes these plan treatment stipulations, and pays unsecured creditors 5% of their claims over 5 years. We took a company that was being strangled by a default judgment and hard money loans and gave it new life.

On December 9, 2020, my Senior Associate Attorney Sofya Davtyan and I confirmed a plan of reorganization in a Chapter 11 case entitled In re C2 Plumbing, Inc, Case No.: 2:19-bk-23459-VZ. The catalyst for the filing of the case was a plumbing job gone wrong for a hotel. This led to the filing of a lawsuit against the debtor by the general contractor on the job and the insurance company that paid out on a million dollar plus claim. A secondary factor in the filing of the Chapter 11 case was the debtor’s liability for approximately $200,000 in prepetition payroll taxes. Debtor’s state court litigation counsel was unable to resolve the state court litigation case. I resolved it through Chapter 11 without the debtor paying any money whatsoever to the Plaintiffs! The bankruptcy filing stayed the litigation. I worked out a deal with Plaintiff’s counsel whereby my client stipulated to relief from stay on the condition that Plaintiffs limit any recovery to insurance proceeds only. In doing so, I made a lethal threat to the company disappear. The debtor’s priority tax obligations will be paid out over 5 years. The payment of these priority taxes enabled the debtor to settle its remaining $91,911.97 in unsecured debt claims over 5 years at a more than 50% discount. Overall, another excellent result for our client!

On October 28, 2020, I confirmed a plan of reorganization and obtained the order of discharge in a Chapter 11 case entitled In re Unified Protective Services, Inc, Case No.: 2:19-bk-16482-NB. The plan allows the Debtor to settle its general unsecured debt totaling $9,420,330.89 by paying 1 cent on the dollar (1% over 5 years!) while paying the priority taxes that it owes over 5 years from the petition date. The Debtor filed this Chapter 11 bankruptcy due to 14 pending state court lawsuits filed against it, including wage and hour class action lawsuits, personal injury lawsuits, and racial harassment and discrimination claims. By hiring us and filing Chapter 11 bankruptcy, Unified avoided lengthy and expensive state court litigation, resolved all of the claims against it and continued the operation of its business without any interruption. This is an astonishingly great result for our client! We did all this over the strong objections of class action counsel for the labor law Plaintiffs.

On July 20, 2020, I confirmed a plan of reorganization in a Chapter 11 case entitled In re Edmond Melamed and Rozita Melamed, Case No.: 2:18-bk-22426-NB. The plan allows the Debtors to keep their principal residence, offer a repayment plan to the Internal Revenue Service, and end the years-long state court litigation filed by secured judgment creditor Mazakoda, Inc. against the Debtors for $1,195,200.00, the related appeal, and the adversary proceeding for denial of discharge. At the time of the filing of this Chapter 11 bankruptcy, Mazakoda, Inc. had already obtained a judgment for judicial foreclosure and a writ of sale had been issue directing the Sheriff to sell the Debtors’ home at auction. I was able to reach a Settlement Agreement with Mazakoda, Inc. which resolved the pending state court litigation, the appeal and the adversary proceeding by paying Mazakoda, Inc. $285,000 over 75 months at 0% interest. By filing the Chapter 11 bankruptcy and confirming the plan, the Debtors were able to stop the foreclosure on their property and avoid the expense and likely adverse results of the appeal. Debtors’ plan offers 23.5% to their general unsecured creditors over 5 years.

On January 23, 2020, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Exie Marie Leagons, Case No.: 2:18-bk-17859-VZ. I was able to reach claim treatment stipulations with the Debtor’s secured creditors regarding the Debtor’s principal residence and her three rental properties. The treatments called for fixing the interest rates for the rental properties, extending the maturity date for one of the loans, and allowing the Debtor to pay off the arrears under manageable terms. I was able to get a consensual plan, whereby all impaired classes voted in favor of confirmation of Debtor’s plan.

On November 27, 2019, I confirmed a plan of reorganization in a Chapter 11 case entitled In re Damu Vusha and Akiba Vusha, Case No.: 2:18-bk-11284-ER. The plan allows the Debtors to repay their creditors over 5 years while keeping their principal residence and two rental properties. The Debtors filed this Chapter 11 bankruptcy due to the pending foreclosure sale on their principal residence by Wells Fargo Bank. At the time of the filing of the Chapter 11 bankruptcy case, Debtors had a pending state court lawsuit against Wells Fargo for denial of loan modification, which they filed in 2016. I was able to reach a Settlement Agreement with Wells Fargo Bank which resolved the pending state court litigation and modified the Debtors’ existing loan terms by reducing the variable 5.5% interest rate to 3% fixed interest rate and adding the $167,050.46 in pre-petition arrears to the principal balance of the loan to be repaid over 228 months. By filing the Chapter 11 bankruptcy and confirming the plan, the Debtors were able to stop the foreclosure on their property and avoid the expense and likely adverse results of taking the state court case to trial.

On October 11, 2019, I confirmed a plan of reorganization in a Chapter 11 case entitled In re Ameriquest Security Service, Case No.: 2:18-bk-21241-WB. The plan allows the Debtor to settle its general unsecured debt totaling $1,121,506.34 by paying 8 cents on the dollar (7.9% over 5 years). The Debtor filed this Chapter 11 bankruptcy due to several pending state court wage and hour class action lawsuits against the Debtor. On January 24, 2020, the Court entered its Order of Discharge – Chapter 11 in the In re Ameriquest Security Service case. By filing the Chapter 11 bankruptcy and confirming the plan, the Debtor avoided lengthy and expensive state court litigation and instead continued the operation of its business without any interruption. We have had great success for our business clients targeted by labor law claims. In some cases, we have been able to use the threat of filing Ch 11 bankruptcy to settle these labor law claims at a greatly reduced cost. In other cases, like this one, we have filed Ch 11 and achieved outstanding results for our clients.

On April 23, 2019, I confirmed a plan of reorganization in a Chapter 11 case entitled In re John Wilcox and Gwenn Wilcox, Case No. 2:17-bk-24446-SK. The plan allows the Debtors to settle their general unsecured debts of $1,238,073.21 by paying 5.4 cents on the dollar (5.4% over 5 years). The Debtors filed this Chapter 11 bankruptcy due to the pending foreclosure sale on one of their rental properties and state court lawsuits filed by Direct Capital and Next Gear against the Debtors for a business debt personally guaranteed by the Debtors. By filing the Chapter 11 bankruptcy and confirming the plan, the Debtors were able to stop the foreclosure of their property, avoid the expense and likely adverse results of taking the state court cases to trial and eliminate 94.6% of their unsecured debt.

On October 4, 2018, I confirmed a plan of reorganization in a Chapter 11 case entitled In re Zenah Essayli, Case No. 8:17-bk-14597-CB. The plan allows the Debtor to settle her general unsecured debts of $1,166,540.14 by paying 18 cents on the dollar (18 % over 5 years). The Debtor filed this Chapter 11 bankruptcy due to two pending state court lawsuits filed by American Express against the Debtor for a business debt personally guaranteed by the Debtor. By filing the Chapter 11 bankruptcy and confirming the plan, the Debtor was able to avoid the expense of taking the state court cases to trial and get a much better result. Instead of having a large judgment against her for the full amount due and a judgment lien against her home, she settled with Amex and her other creditors for 18 cents on the dollar payable over 5 years, with no judgment against her and no judgment lien attached to her home. She is now focused on the on successful operation of her business.

On August 20, 2018, I confirmed a plan of reorganization in a Chapter 11 case entitled In re Union County Transport Inc., Case No.: 2:17-bk-21514-BB. The plan allows the Debtor to settle its general unsecured debt totaling $273,826 by paying 10 cents on the dollar (10% over 5 years). The Debtor filed this Chapter 11 bankruptcy due to a pending state court wage and hourly class action lawsuit against the Debtor. By filing the Chapter 11 bankruptcy and confirming the plan, the Debtor avoided lengthy and expensive state court litigation and instead continued the operation of its business without any interruption. I am seeing large numbers of businesses targeted by labor law claims and have had great success in using the threat or the reality of Chapter 11 cases to greatly reduce the cost of these labor law claims. Union County Transport Inc. received its Order of Discharge on August 27, 2018.

On April 24, 2018, I confirmed a plan of reorganization in a Chapter 11 case entitled In re Shahla Dowlati, Case No. 1:16-bk-10073. The plan allows the Debtor to settle her general unsecured debts of $1,882,151.18 by paying a penny on the dollar (1%) over 5 years! The confirmed plan also included the successful modification of loans on Debtors’ residence and on Debtor’s rental property. Shahla received her Order of Discharge on July 18, 2018.

On October 24, 2017, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Rescue One Ambulance, Case No.: 2:17-bk-10102-NB. Rescue One provides medical transportation services. When Rescue One hired me, it was on the verge of being shut down by the IRS for failure to pay payroll taxes. In addition, it had several years of tax returns that were unfiled and other years of tax returns that needed to be amended. Its owner was facing substantial personal liability for the trust fund portion of these unpaid payroll taxes. By filing tax returns for unfiled years and by amending tax returns, the Debtor got the IRS to reduce its claim by approximately $200,000.00. I negotiated a plan treatment stipulation with the IRS. This stipulation allowed Rescue One to pay back the priority portion of its payroll tax liability over 5 years from the bankruptcy petition date and allowed it 7 years to repay the remaining secured part of the IRS claim. The plan was confirmed without any objections by any creditors. Debtor’s general unsecured creditors are set to receive 5% of the total amount of their claims pursuant to the confirmed Plan. Rescue One is still in business today because of the work done by me and my employees.

On July 10, 2017, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Amos Acoff, Case No.: 2:16-bk-10109-VZ. This case involved the successful reorganization of the loans on the Debtor’s primary residence and six rental properties.  I was able to reach claim treatment stipulations with Debtor’s secured creditors, including the Internal Revenue Service, for treatment of their claims, which included reducing and fixing the interest rates for the rental properties and successfully bifurcating the loans for two of the Debtor’s rental properties, stripping off approximately $135,000. I was able to get a consensual plan, whereby all impaired classes voted in favor of confirmation of Debtor’s plan, which pays only 5% over 5 years to the Debtor’s general unsecured creditors who were owed $180,259. On April 10, 2020, the Court issued its Order of Discharge – Chapter 11.

On June 14, 2017, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Bbeautiful LLC, a California LLC, Case No. 2:16-bk-10799-ER. The Debtor is a brand-maker and retailer of a wide range of personal beauty products for skin, hand & nail, body, hair, pedicure, makeup, and fragrance. Prior to the commencement of its chapter 11 case, and for the first several years of its existence, the Debtor was unable to operate at a profit. Prior to filing Chapter 11, BBeautiful was involved in numerous legal disputes, including several lawsuits. On January 8, 2016, the lawsuit Too Faced Cosmetics, LLC v. Bbeautiful, LLC & Chrislie Formulations, LLC, Case No. 8:16-cv-00033-JLS-DFM (C.D. Cal.) was commenced against the Debtor. The Too Faced Lawsuit included claims alleging violations of Section 43 of the Lanham Act and common law trade dress infringement. The case was stayed by the bankruptcy filing on February 8, 2016. Too Faced Cosmetics, LLC filed a Proof of Claim in the bankruptcy proceeding for $290,729.29. Through negotiations within the Chapter 11 bankruptcy, this claim was reduced to $50,000.00. A million dollar claim from a former employee Xi Zhang was withdrawn entirely. I objected to an alleged breach of contract claim from Ocean Blue, Inc. for $26,213.00, and the Court sustained my objection, disallowing the claim. Under the confirmed plan, general unsecured creditors with allowed claims will receive 50% of their claim in 10 equal quarterly installments.

On February 12, 2016, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Bucur Rentals, LLC. Case No. 6:14-bk23216. I filed a Valuation Motion for Bucur Rentals, LLC with regards to its principal asset, real property located at 2785 Rubidoux Boulevard, Riverside California 92509. Through negotiations with the lender Fidelity Mortgage Lenders, Inc., I was able to reduce the amount of secured debt on the property by $153,053.90. Bucur Rentals, LLC generates income by leasing monthly parking places to trucks and trailers on the Rubidoux Property. The plan pays 1.627 cents on the dollar to all of debtor’s unsecured creditors. I settled $174,084.78 in general unsecured claims by paying a total of $2,883.00 at $48.06/month over five years. That’s pretty good! I entered into a stipulation with the Riverside County Tax Collector to get the vote that we needed to confirm debtor’s Plan of Reorganization. A final decree was entered on May 11, 2017

On February 12, 2016, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Edward D. Roane, Case No.1:14-bk-15621-VK.  Mr. Roane is a successful,  experienced general contractor that ran into problems on a construction project.  Unanticipated costs and disputed change orders left him without the funds needed to complete the project. His main creditor came after him, claiming a liability of $388,420.00.  47 other creditors, many related to the same project, had claims against him as well.  His total unsecured debt was $677,230.32.  I settled all of these claims for 30.2 cents on the dollar payable over five years. Like the vast majority of my Chapter 7, Chapter 11 and Chapter 13 clients, Mr. Roane kept all of his property.

On December 23, 2015, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Steven A. Sassoon and Julie A. Sassoon, Case No.  2:14-bk-12637-TD.  The plan allows the debtors to settle their general unsecured debts totaling $457,721.00 by paying 4.71 cents on the dollar (4.71% over 5 years).  The Debtors filed this Chapter 11 bankruptcy due to a $400,000.00 state court judgment entered against them and in favor of Ronald Shaffer and Debbie Shaffer after 2 appeals and ten years of  litigation with other counsel.  I negotiated a settlement with the Shaffers for $65,000.00 and created a separate impaired class in our Chapter 11 Plan for this debt so we could use this settlement to help confirm our Plan of Reorganization for the Sassoons. The Sassons received their Final Decree and  Order of Discharge on October 19, 2016.

On March 11, 2015, I confirmed a plan of reorganization in a Chapter 11 case entitled, In re Michael J. Parker and Cristina M. Parker, case no. 6:13-3051-MJ. The plan allows the Debtors to settle their general unsecured debts totaling over $1,100,000.00 by paying a penny on the dollar (1%) over 5 years! The confirmed plan also included the successful modification of the loans on Debtors’ residence, vehicles, and boat. I also settled four state court lawsuits for Mr. Parker and his business.  On April 30, 2015, the Final Decree was entered and the Debtors received their Order of Discharge.

On October 28, 2014, I confirmed a plan of reorganization in a Chapter 11 case entitled In re Nabih Mansour and Mary Mansour, Case No. 2:12-bk-48622-RN. The Mansours filed a Chapter 11 bankruptcy to stop a scheduled foreclosure sale of their home.  Dr. Nabih Mansour is a veterinarian. He owns and operates N&M Evergreen Hospital, Inc.  Mary Mansour is a pharmacist.  Prior to filing bankruptcy, the Mansours and their company filed a construction defects complaint against MK Construction (“MK”) and certain other Defendants. MK filed a $806,107.78 Proof of Claim in the Mansours’ bankruptcy case and filed an Adversary Proceeding Complaint against the Mansours to make their alleged debt nondischargeable. With the help of our law firm, the Debtors completed a global settlement which resulted in the Mansours  receiving $939,000.00 from MK and the other defendants.  The Adversary Proceeding that MK filed against the Mansours was dismissed with prejudice, with no payment to MK.   The Mansours used part of their settlement money to pay off their creditors, including  payment of back taxes owed to the IRS and payment of a  large arrearage on their home mortgage. The Mansours kept their home, favorably settled their state court litigation, and settled all of their  debts.

On August 24, 2012, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Hoskins Enterprises, Inc., Case No. 1:11-bk-15148-GM. Hoskins Enterprises, Inc. provides adult day care services for mentally disabled adults. Its principal place of business is at 426 E. 99th Street, Inglewood, CA 91301. Debtor was forced into bankruptcy by a wrongful termination lawsuit from Angela Grundy and a liability for unpaid payroll taxes due to the IRS and the EDD. I settled the Grundy claim and entered into a plan treatment stipulation with Ms. Grundy whereby Ms. Grundy reduced her claim from $277,500 in damages to $55,000.00 to be paid in quarterly payments over 5 years. General unsecured claims totaling $390,100.28 were paid 19.8 cents on the dollar. The owners of Hoskins Enterprises retained 100% of their ownership interest in Hoskins Enterprises, Inc.

On May 5, 2014, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Ruth Hasson, Case No. 2:13-bk-15138-RK.  When the Debtor hired me, she wanted only one thing: to save her home from being lost in foreclosure. We saved her home. The day before the trustee sale, we filed a Chapter 11 petition.  We stipulated to plan treatment with the lender that holds the First Deed of Trust on her home and settled her unsecured debts at a large discount, with payments to be made over 5 years.  A Final Decree was entered on September 25, 2014.

On December 11, 2013, I confirmed a plan of reorganization in a Chapter 11 Case entitled, In re Martha Gutierrez and Aaron Gutierrez, Case No # 2:12-bk-32047-WB. This case involved the successful reorganization of the loans on the Debtors’ two rental properties.  I was able to successfully value both properties in order to strip off secured liens in the approximate amount of $464,398.00. I was also able to obtain a consensual plan amongst all of the Debtors’ creditors and pay the general unsecured creditors, who were owed approximately $1,055,000.00, only 1% over 5 years.  On May 30, 2014, the Debtors obtained their Order of Discharge.

On November 6, 2013, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Jamal Elyazal, case number 6:12-bk-11709-MW. This case involved the successful reorganization of the loans on the Debtor’s primary residence and his 17 rental properties. I was able to successfully value the debtor’s properties in order to bifurcate the secured claims on all three of the Debtors’ income properties as well as the second lien on Debtors’ primary residence, stripping off approximately $4,400,000.00 in secured liens. I was also able to successfully cram down the objecting classes and pay only 1% over 5 years to the debtor’s general unsecured creditors who were owed approximately $6.2 million. This case set the record in the Santa Ana Division of the Central District for most properties reorganized in an individual Chapter 11 case.  A Final Decree was entered on March 19, 2014. An order of Discharge was entered on March 15, 2018.

On October 1, 2013, I confirmed a plan of reorganization in a Corporate Chapter 11 Case entitled In re CDG Materials, Inc., Case No.: 6:12-bk-12935-MH. This case involved the successful reorganization of a corporation principally engaged in the business of manufacturing and selling various types and grades of gravel and sand. For over 28 years, the debtor was a well-known and trusted name within the construction community for its high-quality production of sand, gravel and crushed rock. The debtor’s reputation was compromised and nearly lost when the corporation’s income was overwhelmingly outweighed by its liabilities to various creditors. I successfully negotiated plan treatment stipulations with the debtor’s main creditors and convinced 100% of the creditors that voted on the plan to accept the plan. The plan was successfully confirmed, with general unsecured creditors receiving only 2.82% of the total amount of their debt.

On June 5, 2013, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Vicente Zarate and Ingrid R. Zarate, Case No.: 2-12-bk-16597-PC. This case involved the successful reorganization of the loans on the Debtors’ primary residence and their multiple rental properties. The Plan also provided for the successful sale of one of their income properties. I was able to successfully value the debtors’ properties in order to bifurcate the secured claims on all three of the Debtors’ income properties as well as the second lien on Debtors’ primary residence, stripping off approximately $3,416,000.00 in secured liens. I was also able to successfully cram down the objecting classes and pay only 1% over 5 years to the debtors’ general unsecured creditors who were owed approximately $7.2 million.  On June 16, 2015, the Debtors obtained their Order of Discharge.

On May 10, 2013, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Alejandro Caray Casasola and Zenaida Urmanita Casasola, Case No. 2:11-bk-47034-ER. When the Debtors hired me, they wanted three things: to keep their primary residence, to strip the second lien of $325,000.00 on their primary residence, and to work something out with Wells Fargo regarding a $500,000.00 debt. I stipulated to plan treatment with the first on Debtors’ primary residence, got the second on Debtors’ primary residence forgiven in full, and settled the Debtors’ total unsecured debts of approximately 1 million dollars, including the $500,000.00 Wells Fargo claim, by paying out only six cents on the dollar over 5 years. My clients got everything that they wanted.  A Final Decree was entered on August 28, 2013.

On May 1, 2013, I confirmed a plan of reorganization in a Consolidated Chapter 11 Case entitled In re Steven Michael Mehr and Larissa Deshaviegh Mehr, lead case number 8:11-bk-12166-ES, consolidated case number 8:11-bk-17014-ES. This case involved the successful reorganization of debtors’ primary residence in Orange County and 7 rental properties located throughout Orange County and Los Angeles County. The debtors wanted to keep all of their properties as a retirement plan for their future. I successfully brought and prevailed on 8 valuation motions that reduced the amount of the secured first lien on each of debtors’ investment properties, and completely unsecured the second lien on each of debtors’ properties. With over 90 creditors, I resolved numerous disputes related to creditors’ claims, including one with the City of Cudahy. The plan was confirmed with a favorable ballot received from every secured creditor in the bankruptcy, with general unsecured creditors receiving only 1.00% of the total amount of their debt.  A Final Decree was entered on April 7, 2014.

On March 27, 2013, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Arthur Melnikov and Alina Kutsevol, Case No.: 1:11-bk-11614-GM. This was a personal Chapter 11 for individual Debtors that owned a home and two rental properties. The Debtors were in bankruptcy for 15 months before they hired me. During that time, there was little or no progress on their case. After Debtors retained my services, I successfully reduced the Debtors’ secured debt on their principal residence by $201,153.00 by successfully bringing a Lien Avoidance Motion pursuant to 11 U.S.C. §506(d). I was also successful in reducing Debtors’ secured debts on their Mammoth Rental property by $280,000.00 by successfully bringing a Motion for Order to Value Collateral and Wholly Avoid Security Interest of Junior Trust Deed Holder, and by bifurcating/partially avoiding the secured interest of the first trust deed holder. Debtors were able to keep all three properties. A Final Decree was entered on September 9, 2013. An Order of Discharge was entered on November 15, 2016.

On December 17, 2012, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Ovazine Yvette Shannon, Case No.:2:11-bk-38912-VZ. This case involved the successful reorganization of debtor’s six multi-unit apartment building rental properties. The debtor came to me after filing three prior unsuccessful Chapter 11 bankruptcies with two different attorneys. Filing the debtor’s fourth Chapter 11 bankruptcy, I successfully overcame a 180-day bar. I then brought and prevailed on six valuation motions that reduced the amount of the secured first lien on all six rental properties, and completely stripped off the second liens on properties that had seconds, thereby rendering them completely unsecured. The plan treatment of unsecured creditors paid out seven cents on the dollar for over 5 years.

On July 23, 2012, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Richard G. Miller and Shannon Miller,  Case No # 6:10-bk-31105-MJ. This was a personal Chapter 11 bankruptcy case for a retired, married couple that owned a home, rental property, and vacant land.   I reduced the Debtor’s secured debt on their home by $255,000.00 by successfully bringing a Motion for Order to Value Collateral and Avoid Security Interest.  Debtors kept all of their property.  The vacant land was re-purposed to produce agricultural income. A final decree was entered on January 28, 2013.

On June 29, 2012, I confirmed a plan of reorganization in a Chapter 11 Case Name Withheld, Case No # 1:10-bk-23818-GM. This was a personal Chapter 11 for an individual Debtor. The Debtor was in bankruptcy for 16 months before he hired me.  During that time, there was little or no progress on his case.   After the debtor hired me, I reduced his secured debt by $568,000.00 as the result of a half day evidentiary hearing before Judge Mund, and, in less than four months, I confirmed a plan of reorganization for him that resolved all of his problems and let him keep his home and all of his rental properties.

On June 29, 2012, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Leonor C Zimerman, Case No.: 1:11-bk-14045-GM. This case involved the successful reorganization of the loans on the Debtor’s primary residence and her rental property. I was also able to successfully value the residence in order to strip off the secured second lien in the amount of $184,826.43 and make that loan fully unsecured. A final decree was entered on January 7, 2013.

On June 13, 2012, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Vahigh and Penah Dadayan, Case No.: 2-11-bk-14452-RK.  This was a personal Chapter 11 for a couple that wanted to keep their home and 5 rental properties.  I successfully brought multiple valuation motions and reduced the secured debt on debtors’ rental properties.  My clients restructured their debts and kept ALL of their properties. A final decree was entered on May 15, 2013.

On May 23, 2012, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Hamid Doe and Farideh Doe, Case No.: 1-11-bk-17414-AA. This case involved the successful reorganization of the loans on the Debtors’ primary residence. I prepared and won a Motion for Order to Value Collateral with regards to the Debtors’ home, successfully stripping off the second and third liens on the home.  By doing this, I changed a combined $258,063.00 in debt from secured debt to unsecured debt.  The plan that I confirmed settles all of the Debtors’ unsecured debt by paying out less than one penny on the dollar to Debtors’ unsecured creditors over 5 years. A Final Decree was entered on June 4, 2013.

On April 11, 2012, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Gregory Stephen Jones, Jr. and Eteva Desiree Laufasa, Case No.: 2:11-bk-22829-PC. This case involved the successful reorganization of the loans on the Debtors’ primary residence and both of their rental properties. I was able to successfully value the residence in order to strip off the secured second lien in the amount of approximately $221,000.00 and make that fully unsecured. I was also able to successfully value one of the rental properties in order to strip off approximately $156,000.00 and make that completely unsecured. On the second rental property, I was able to value the property in order to settle the second lien in approximate amount of $133,000.00 and strip it off for only $5,000.00.  A Final Decree was entered on October 3, 2012.  An Order entering Discharge was entered on October 15, 2014.

On February 27, 2012, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re 7 West, LLC, Case # 2:10-bk-36804-ER. This case involved the successful reorganization of a 24 unit apartment complex in Los Angeles, California. A Final Decree was entered on May 10, 2013.

On February 3, 2012, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Moshe Segev and Michelle M. Cohen, Case # 1:09-bk-23222-GM. This was a personal Chapter 11 for a couple with 4 children under the age of 9. I successfully brought multiple valuation motions and reduced the secured debt on debtors’ investment properties. My clients restructured their debts and kept 4 out of 6 properties.

On September 30, 2011, I confirmed a plan of reorganization in a Chapter 11 Case entitled In re Ludo Gust Mensch and Lorraine Patricia Mensch, Case No.: 1:10-bk-22102-MT. This case involved the successful reorganization of a construction company and two pieces of real property.

On July 18, 2011, I confirmed a plan of reorganization in a Chapter 11 case entitled In re Rahim Zabihi, Case No. 8-10-bk-11504-TA. That case involved the successful reorganization of two veterinarian clinics and five pieces of real property. A Final Decree was entered on November 7, 2012. Mr. Zabihi completed all of his plan payments and, on May 26, 2016, Judge Theodor Albert granted our Motion to Enter Discharge of the Debtor.

On July 7, 2011, I confirmed a plan of reorganization in a Chapter 11 case entitled In re Twelve Signs Incorporated, Case No. 2:10-bk-11758-PC. This case involved the liquidation of various intellectual property of an astrological products company, including the magazine “Star Scroll.” A Final Decree was entered on March 20, 2012.

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