Application
description
Transcript of 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)
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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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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