Application

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82691v.2 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT HARTFORD DIVISION IN RE: CURTIS JAMES JACKSON, III, DEBTOR. § § § § § CHAPTER 11 CASE NO. 15-21233 (AMN) DEBTOR’S MOTION FOR ORDER EXTENDING THE TIME TO FILE HIS SCHEDULES OF ASSETS AND LIABILITIES AND STATEMENT OF FINANCIAL AFFAIRS Curtis James Jackson, III (the “Debtor”), the debtor and debtor in possession in the above-captioned bankruptcy case (the “Bankruptcy Case”) under chapter 11 of title 11 of the United States Code, 11 U.S.C. §§ 101-1532, as amended (the “Bankruptcy Code”), 1 files this motion (the “Motion”) for an order extending the time for him to file his Schedules of Assets and Liabilities (the “SOAL”) and Statement of Financial Affairs (the “SOFA”) and, in support, states as follows: I. Jurisdiction and Venue 1. Petition Date and Creditors’ Meeting. The Debtor filed his voluntary petition for relief under chapter 11 of the Bankruptcy Code on July 13, 2015 (the “Petition Date”), thereby initiating this Bankruptcy Case. The creditors’ meeting under § 341(a) is scheduled for August 7, 2015. 2. Continued Operations. Under § 301, the filing of the petition constituted an order for relief under chapter 11 and, since that filing, under §§ 1107 and 1108, the Debtor has continued in possession and control of his assets and property and has continued to operate his business and manage his affairs. 1 All of the section references not otherwise defined herein will be to the Bankruptcy Code. Case 15-21233 Doc 30 Filed 07/21/15 Entered 07/21/15 18:27:24 Desc Main Document Page 1 of 8

description

Application

Transcript of Application

  • 82691v.2

    IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT

    HARTFORD DIVISION

    IN RE: CURTIS JAMES JACKSON, III, DEBTOR.

    CHAPTER 11 CASE NO. 15-21233 (AMN)

    DEBTORS MOTION FOR ORDER EXTENDING THE TIME TO FILE HIS SCHEDULES OF ASSETS AND LIABILITIES AND

    STATEMENT OF FINANCIAL AFFAIRS

    Curtis James Jackson, III (the Debtor), the debtor and debtor in possession in the

    above-captioned bankruptcy case (the Bankruptcy Case) under chapter 11 of title 11 of the

    United States Code, 11 U.S.C. 101-1532, as amended (the Bankruptcy Code),1 files this

    motion (the Motion) for an order extending the time for him to file his Schedules of Assets and

    Liabilities (the SOAL) and Statement of Financial Affairs (the SOFA) and, in support, states

    as follows:

    I. Jurisdiction and Venue

    1. Petition Date and Creditors Meeting. The Debtor filed his voluntary petition for

    relief under chapter 11 of the Bankruptcy Code on July 13, 2015 (the Petition Date), thereby

    initiating this Bankruptcy Case. The creditors meeting under 341(a) is scheduled for August

    7, 2015.

    2. Continued Operations. Under 301, the filing of the petition constituted an order

    for relief under chapter 11 and, since that filing, under 1107 and 1108, the Debtor has

    continued in possession and control of his assets and property and has continued to operate his

    business and manage his affairs.

    1 All of the section references not otherwise defined herein will be to the Bankruptcy Code.

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    3. Jurisdiction. This Court has jurisdiction to hear this matter under 28 U.S.C.

    157 and 1334(b). This is a core proceeding under 28 U.S.C. 157(b)(2).

    4. Venue. Venue is proper before this Court in this district under 28 U.S.C. 1408

    and 1409.

    II. Factual Background

    5. The Debtor, Curtis James 50 Cent Jackson, III, is an internationally recognized

    recording artist, an actor, an entrepreneur and a philanthropist. Since his entrance onto the music

    scene in 2003 with his multi-platinum debut album, the Debtor has sold more than 22 million

    albums worldwide, and has received numerous awards and Grammy nominations throughout his

    career.

    6. As a result of the Debtors success, he has been fortunate to acquire a significant

    amount of assets. Like many other celebrity entertainers that make their living in full view of the

    public eye, however, the Debtor has accumulated a substantial amount of liabilities as well.

    Notwithstanding this fact, the Debtors bankruptcy filing is not primarily a result of excessive

    current expenses exceeding his current revenues, but rather the substantial costs of litigation and

    resulting awards against him in the past year which total in excess of $20 million. While the

    Debtor has substantial assets, he does not have the ability to pay the full amount of these

    litigation claims and all other asserted claims at the present time, thereby necessitating this

    chapter 11 filing.

    7. The Debtor filed his chapter 11 petition to obtain the full protections of the

    bankruptcy laws in order to reorganize his financial affairs in a reasonable and timely manner

    and in accordance with an approved plan for the benefit of his estate and all of his creditors. In

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    connection with this bankruptcy proceeding, the Court will determine the extent and value of the

    Debtors assets and liabilities and, thus, Debtors net worth.

    III. Relief Requested

    8. Under 521 and Rule 1007(c) of the Federal Rules of Bankruptcy Procedure (the

    Bankruptcy Rules), the Debtor is required to file his SOAL and SOFA within 14 days of the

    Petition Date. Because the Petition Date was July 13, 2015, the current deadline for the Debtor

    to file his SOAL and SOFA is July 27, 2015.

    9. By this Motion, the Debtor requests that this Court, for the reasons set forth

    below, extend the 14-period to file his SOAL and SOFA for an additional 7 days until August 3,

    2015, without prejudice to the Debtors ability to request additional time should it become

    necessary.

    IV. Cause Exists For an Extension of Time to File the SOAL and SOFA

    10. The Debtors business operations are run through numerous corporate entities that

    he has an interest in (collectively, the Related Entities), and that include the following:

    ENTITY OPERATIONS OF THE RELATED ENTITY Curtis James Jackson, III Financial advisory and accounting services

    Cheetah Vision Inc. Television shows and movies

    Tomorrow, Today Entertainment Inc. Website (thisis50.com)

    G-Unit Film and Television Inc. Film company

    G-Unit Touring Inc. Touring company

    G-Unit Brands Inc. Endorsement deals

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    ENTITY OPERATIONS OF THE RELATED ENTITY Rotten Apple Records Inc. Royalties, side artists, publishing

    50s Liquid Assets Inc. Royalties

    G-Unit Merchandising Inc. FEA deal tour only

    G-Unit Books Inc. Book deals, royalties

    G-Unit Adult Films Inc. Production of adult films, royalties

    G-Unit Records Inc. Label, office, salaries

    G-Unity Foundation Inc. Charity

    Hollow Point Inc. Corporate entity not presently used

    Love Me Love Me Not Short Film LLC Short film, royalties

    Things Fall Apart LLC Short film, royalties

    In the Passing Lane LLC Ownership of automobiles, payment of drivers, all car-related expenses

    Before I Self Destruct Short Film LLC Short film, royalties

    G-Unit Clothing LLC Inactive corporate entity, but possible new clothing deal in the works

    50 Cent Music LLC Inactive corporate entity

    CT Lights LLC Connecticut home expenses and mortgage, Los Angeles rental property

    SMS Promotions, LLC Promotion of boxers, and the operations of a Las Vegas, Nevada gym

    Animal Ambition Short Film LLC Inactive corporate entity

    Street King LLC The Debtor made an investment in this entity through 50s Liquid Assets Inc.

    TMT Promotion LLC Inactive corporate entity that previously handled boxing promotion for Floyd Mayweather

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    ENTITY OPERATIONS OF THE RELATED ENTITY Tomorrow, Today Short Film LLC Inactive corporate entity

    Sire Spirits LLC Effen Vodka / Beam deal

    Broadway Boxing LLC Inactive corporate entity that is slated to be involved with boxing promotions in the future

    CJJ Enterprises LLC Inactive corporate entity

    SMS Audio LLC Headphones

    SMS Kono Audio LLC Headphones

    G Note Records, Inc. Recording deals

    11. Due to the number of the Related Entities, the complexity of the Debtors books

    and records, and the potential volume of materials to be included in his SOAL and SOFA, the

    Debtor will be unable to complete his SOAL and SOFA within the 14 days mandated under

    Bankruptcy Rule 1007(c), and he requires an additional seven (7) days, or until August 3, 2015.

    12. The Debtor submits that this Motion is being filed in good faith and will not

    prejudice the rights of any creditors or parties in interest.

    13. No previous request for the relief sought herein has been made to this or any other

    court.

    V. Prayer

    The Debtor prays that this Court grant this Motion by issuing an order that extends the

    deadline for the Debtor to file his SOAL and SOFA an additional 7 days, until August 3, 2015,

    and awards the Debtor such other and further relief, special or general, at law or in equity, as this

    Court may deem just and proper.

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    Dated: July 21, 2015 Respectfully submitted,

    NELIGAN FOLEY LLP /s/ Patrick J. Neligan, Jr. Patrick J. Neligan, Jr. Texas State Bar No. 14866000 [email protected] James P. Muenker Texas State Bar No. 24002659 [email protected] 325 N. St. Paul, Suite 3600 Dallas, Texas 75201 Telephone: (214) 840-5300 Facsimile: (214) 840-5301 ZEISLER & ZEISLER P.C. /s/ James Berman James Berman CT Bar No. 06027 [email protected] 10 Middle Street, 15th Floor Bridgeport, Connecticut 06604 Telephone: (203) 368-4234 Facsimile: (203) 367-9678 PROPOSED COUNSEL TO THE DEBTOR

    Certificate of Service

    The undersigned counsel hereby certifies that the 21th day of July, 2015, a true and correct copy of the foregoing was via first class mail upon the persons named on the attached Service List and electronically via this Courts ECF notification system.

    /s/ Patrick J. Neligan, Jr. Patrick J. Neligan, Jr.

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  • 82712v.1

    MASTER SERVICE LIST Curtis James Jackson, III

    PROPOSED DEBTORS COUNSEL

    Patrick J. Neligan, Jr. James P. Muenker Neligan Foley LLP 325 N. St. Paul, Suite 3600 Dallas, TX 75201

    James Berman Zeisler & Zeisler P.C. 10 Middle Street, 15th Floor Bidgeport, CT 06604

    DEBTOR

    Curtis James Jackson, III c/o Nikki Martin G-Unit Records, Inc. 264 West 40th Street, 15th Floor New York, NY 10018

    U.S. TRUSTEE

    Office of the United States Trustee Attn: Kim McCabe Giaimo Federal Building 150 Court Street, Room 302 New Haven, CT 06510

    GOVERNMENT AGENCIES

    Internal Revenue Service P.O. Box 7346 Philadelphia, PA 19101-7346

    Securities and Exchange Commission 100 F Street, NE Washington, DC 20549

    Internal Revenue Service Centralized Insolvency Operation P.O. Box 21126 Philadelphia, PA 19114-0326

    SECURED CREDITOR

    Suntrust Mortgage P.O. Box 79041 Baltimore, MD 21279

    20 LARGEST UNSECURED CREDITORS

    Sleek Audio, LLC, Mark Krywko, Michael Krywko, Jason Krywko and Gregory WSysocki 3904 9th Avenue West Bradenton, FL 34205

    Lastonia Leviston c/o Darren M. Gelber Wilentz, Goldman & Spitzer 110 William Street, 26th Floor New York, NY 10038

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    Suntrust Bank P.O. Box 79079 Baltimore, MD 21279

    Reed Smith 1901 Avenue of the Stars, Suite 700 Los Angeles, CA 90067

    Robins Kaplan LLP 800 LaSalle Avenue Minneapolis, MN 55402

    Garvey Schubert Barer 100 Wall Street, 20th Floor New York, NY 10005

    Bentley Financial Services 75 Remittance Drive, Suite 738 Chicago, IL 60675

    American Express P.O. Box 1270 Newark, NJ 07101-1270

    G. Collins & Company LLC 1410 Broadway, Suite 1905 New York, NY 10018

    Premium Assignment Corp. P.O. Box 800 Tallahassee, FL 32314

    Dorothy McJesus c/o Michael Malkovich Xanthakos & Malkovich 43 Center Street, Suite 101 Northampton, MA 01060

    Candance Scott c/o Michael Malkovich Xanthakos & Malkovich 43 Center Street, Suite 101 Northampton, MA 01060

    539 38th Street, LLC P.O. Box 685 Hackensack, NJ 07602

    Stephen J. Savva P.C. 546 Fifth Avenue, 6th Floor New York, NY 10036

    Eversource P.O. Box 650032 Dallas, TX 75265-0032

    Erin McSherry 295 Park Avenue S #2G New York, NY 10010

    Moritt Hock & Hamroff 400 Garden City Plaza Garden City, NY 11530

    Feldman and Hickey LLC Waterside Office Park 10 Waterside Drive, Suite 303 Farmington, CT 06032

    Curtis J. Jackson, Sr. 6 West Circle Drive Valley Stream, NY 11581-1517

    8X10 Boutique LLC 2700 N. Miami Avenue, #1001 Miami, FL 33127

    PARTIES REQUESTING NOTICE

    Elizabeth J. Austin Pullman & Comley, LLC 850 Main Street Bridgeport, CT 06604

    Jessica Grossarth Pullman & Comley, LLC 850 Main Street Bridgeport, CT 06604

    Michael R. Enright Robinson & Cole 280 Trumbull Street Hartford, CT 06103

    Patrick M. Birney Robinson & Cole 280 Trumbull Street Hartford, CT 06103

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