The trustee filed a motion seeking court approval of a settlement agreement between the trustee and William Maxwell, William Maxwell PLLC, and William Maxwell PC. William Maxwell had filed proofs of claim for $5.5 million against the bankruptcy estate. The trustee had also sued William Maxwell in an adversary proceeding. Under the proposed settlement agreement, William Maxwell would withdraw his $5.5 million in claims and the trustee would dismiss his claims against William Maxwell. The trustee believes this settlement is in the best interest of the estate to avoid costly litigation, even though he believes he has strong claims, given there are insufficient assets to justify pursuing the claims.
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Federal court denied the motion by Satish Vuppalapati, Madhavi Vuppalapati and Anandhan Jayaraman. Court confirmed that PISL India and PISl PA are one and the same companies.
'Madhavi Vuppalpati & Anandhan Jayaraman defeated in their attempt to derail ...mh37o
Madhavi Vuppalpati and her husband Anandhan Jayaraman are defeated in their attempt to derail the trial in Washington Court with this denial by Hon Madam Justice Marsha j. Pechman
Federal Court Denying Motion by Satish Vuppalapati, Madhavi Vuppalapati and A...mh37o
Federal court denied the motion by Satish Vuppalapati, Madhavi Vuppalapati and Anandhan Jayaraman. Court confirmed that PISL India and PISl PA are one and the same companies.
'Madhavi Vuppalpati & Anandhan Jayaraman defeated in their attempt to derail ...mh37o
Madhavi Vuppalpati and her husband Anandhan Jayaraman are defeated in their attempt to derail the trial in Washington Court with this denial by Hon Madam Justice Marsha j. Pechman
El BoNY consideró las "amenazas" europeas pero mostró fidelidad a su país y le pidieron a Griesa que aclare qué se debe hacer con el dinero argentino, retenido desde el 26 de junio.
Sample California motion to compel further responses to special interrogatoriesLegalDocsPro
This sample California motion to compel further responses to special interrogatories is made pursuant to Code of Civil Procedure Section 2030.300 and is used when a party has served special interrogatories but the responses received are evasive or incomplete, or the objections are without merit or are too general. The sample could easily be modified to apply to form interrogatories as well. The sample on which this preview is based is 30 pages and includes a memorandum of points and authorities with citations to case law and statutory authority, a separate statement as required by Rule of Court 3.1345, a sample declaration and a proof of service by mail.
This a sample offer to compromise or also known as a 998 offer for California is pursuant to Section 998 of the Code of Civil Procedure. This sample is used when a defendant wants to make an offer to compromise to the plaintiff. It can be adapted for use by a plaintiff who wishes to make an offer to compromise to a defendant.
The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.
San Diego attorney Scott McMillan sued Darren Chaker to remove public records about McMillan's being named in a child molestation investigation. The report is contained as an exhibit in San Diego Superior Court Case No. 37-2017-00036344-CU-NP-CTL and can also be seen on this profile.
Nonetheless, Scott McMillan San Diego attorney suffered a miserable loss in San Diego federal court, then appealed the loss to the Ninth Circuit. San Diego attorney Scott McMillan also filed an identical lawsuit in San Diego Superior Court, Case No. 37-2017-00036344-CU-NP-CTL. As expected, the Ninth Circuit found the lawsuit against Darren Chaker was meritless.
Now, San Diego attorney Scott McMillan is facing two anti-SLAPP motions in San Diego Superior Court and of course the inevitable embarrassment of losing his case, which is almost as bad as Scott McMillan having been sued twice recently for fraud and legal malpractice.
Sample collection of meet and confer letters for discovery in californiaLegalDocsPro
This sample collection of meet and confer letters for discovery in California contains over 10 sample meet and confer letters and responses to meet and confer letters including a (1) meet and confer letter for further discovery responses to interrogatories, requests for admission and requests for production of documents, (2) response to meet and confer letter for motion to compel further responses to interrogatories, (3) response to meet and confer letter for motion to compel further responses to requests for production of documents, (4) meet and confer letter for protective order for interrogatories, (5) meet and confer letter for protective order for requests for admission, (6) meet and confer letter for protective order for requests for production of documents, (7) Response to meet and confer letter for for protective order for interrogatories, (8) response to meet and confer letter for protective order for requests for admission, (9) response to meet and confer letter for protective order for requests for production of documents, (10) meet and confer letter for protective order for deposition, (11) meet and confer letter for motion to quash subpoena duces tecum, (12) meet and confer letter for motion to compel attendance at deposition, and (13) meet and confer letter for motion to compel testimony at deposition. The sample on which this preview is based is 42 pages and includes the meet and confer letters mentioned above. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale.
Opposition to a California summary judgment motionLegalDocsPro
This sample opposition to a motion for summary judgment in California was created by a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
El BoNY consideró las "amenazas" europeas pero mostró fidelidad a su país y le pidieron a Griesa que aclare qué se debe hacer con el dinero argentino, retenido desde el 26 de junio.
Sample California motion to compel further responses to special interrogatoriesLegalDocsPro
This sample California motion to compel further responses to special interrogatories is made pursuant to Code of Civil Procedure Section 2030.300 and is used when a party has served special interrogatories but the responses received are evasive or incomplete, or the objections are without merit or are too general. The sample could easily be modified to apply to form interrogatories as well. The sample on which this preview is based is 30 pages and includes a memorandum of points and authorities with citations to case law and statutory authority, a separate statement as required by Rule of Court 3.1345, a sample declaration and a proof of service by mail.
This a sample offer to compromise or also known as a 998 offer for California is pursuant to Section 998 of the Code of Civil Procedure. This sample is used when a defendant wants to make an offer to compromise to the plaintiff. It can be adapted for use by a plaintiff who wishes to make an offer to compromise to a defendant.
The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.
San Diego attorney Scott McMillan sued Darren Chaker to remove public records about McMillan's being named in a child molestation investigation. The report is contained as an exhibit in San Diego Superior Court Case No. 37-2017-00036344-CU-NP-CTL and can also be seen on this profile.
Nonetheless, Scott McMillan San Diego attorney suffered a miserable loss in San Diego federal court, then appealed the loss to the Ninth Circuit. San Diego attorney Scott McMillan also filed an identical lawsuit in San Diego Superior Court, Case No. 37-2017-00036344-CU-NP-CTL. As expected, the Ninth Circuit found the lawsuit against Darren Chaker was meritless.
Now, San Diego attorney Scott McMillan is facing two anti-SLAPP motions in San Diego Superior Court and of course the inevitable embarrassment of losing his case, which is almost as bad as Scott McMillan having been sued twice recently for fraud and legal malpractice.
Sample collection of meet and confer letters for discovery in californiaLegalDocsPro
This sample collection of meet and confer letters for discovery in California contains over 10 sample meet and confer letters and responses to meet and confer letters including a (1) meet and confer letter for further discovery responses to interrogatories, requests for admission and requests for production of documents, (2) response to meet and confer letter for motion to compel further responses to interrogatories, (3) response to meet and confer letter for motion to compel further responses to requests for production of documents, (4) meet and confer letter for protective order for interrogatories, (5) meet and confer letter for protective order for requests for admission, (6) meet and confer letter for protective order for requests for production of documents, (7) Response to meet and confer letter for for protective order for interrogatories, (8) response to meet and confer letter for protective order for requests for admission, (9) response to meet and confer letter for protective order for requests for production of documents, (10) meet and confer letter for protective order for deposition, (11) meet and confer letter for motion to quash subpoena duces tecum, (12) meet and confer letter for motion to compel attendance at deposition, and (13) meet and confer letter for motion to compel testimony at deposition. The sample on which this preview is based is 42 pages and includes the meet and confer letters mentioned above. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale.
Opposition to a California summary judgment motionLegalDocsPro
This sample opposition to a motion for summary judgment in California was created by a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
UNITED STATES' ABUSE OF THE 'SERIAL LITIGATOR' DEFENSEVogelDenise
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IMPORTANT TO NOTE: Are those WHO played ROLES in the FOUNDING of Israel as the Nazis and/or WHITE Jewish/Zionists/Supremacists Law Firms as Baker Donelson Bearman Caldwell & Berkowitz: https://www.slideshare.net/VogelDenise/baker-donelson-founder-of-state-of-israel
The DENIAL of JURY TRIAL is also a defense that may be used in seeking INTERNATIONAL Judicial Review, INVESTIGATIONS and PROSECUTIONS, etc. – i.e. in taking matter(s) before INTERNATIONAL Tribunals!
121815 - OBJECTION TO 120815 ORDER ON OBJECTION (Townsend Matter)VogelDenise
POWER WITH "WE THE PEOPLE" - KNOW YOUR LEGAL/LAWFUL RIGHTS TO OVERTHROW THE UNITED STATES OF AMERICA'S DESPOTISM GOVERNMENT and have a GOVERNMENT that WORKS for "WE THE PEOPLE!"
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REBUTTAL TO 093015 BANKRUPTCY COURT FRIVOLOUS FINAL JUDGMENT - SHELLACKING 10...VogelDenise
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https://www.productmanagementtoday.com/frs/26903918/understanding-user-needs-and-satisfying-them
We know we want to create products which our customers find to be valuable. Whether we label it as customer-centric or product-led depends on how long we've been doing product management. There are three challenges we face when doing this. The obvious challenge is figuring out what our users need; the non-obvious challenges are in creating a shared understanding of those needs and in sensing if what we're doing is meeting those needs.
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Doc1060 william maxwell motion for settlement_walk away
1. _____________________________________________________________________________________________
MOTION FOR ORDER APPROVING COMPROMISE AND SETTLEMENT AGREEMENT
BETWEEN THE TRUSTEE AND WILLIAM MAXWELL, WILLIAM MAXWELL, PLLC, AND
WILLIAM MAXWELL, PC Page 1 of 5
#4819-2741-0481
Eric W. Pinker, P.C. (epinker@lynnllp.com)
Texas Bar No. 16016550
John Volney (jvolney@lynnllp.com)
Texas Bar No. 24003118
LYNN PINKER COX & HURST, LLP
2100 Ross Avenue, Suite 2700
Dallas, Texas 75201
(214) 981-3800 Telephone
(214) 981-3839 Facsimile
ATTORNEYS FOR PLAINTIFF
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
In re: §
§
FIRSTPLUS FINANCIAL GROUP, INC., § Case No. 09-33918-hdh-11
Debtor, § Chapter 11
______________________________________________________________________________
MOTION FOR ORDER APPROVING COMPROMISE AND
SETTLEMENT AGREEMENT BETWEEN THE TRUSTEE AND WILLIAM
MAXWELL, WILLIAM MAXWELL, PLLC, AND WILLIAM MAXWELL, PC
______________________________________________________________________________
NO HEARING WILL BE CONDUCTED ON THIS MOTION UNLESS A WRITTEN
RESPONSE IS FILED WITH THE CLERK OF THE UNITED STATES
BANKRUPTCY COURT AT 1100 COMMERCE, ROOM 12A24, DALLAS, TEXAS
75242-1496, BEFORE THE CLOSE OF BUSINESS ON AUGUST 19, 2016, WHICH
IS MORE THAN TWENTY-FOUR (24) DAYS FROM THE DATE OF THIS
MOTION’S SERVICE.
ANY RESPONSE MUST BE IN WRITING AND FILED WITH THE CLERK, AND A
COPY MUST BE SERVED UPON COUNSEL FOR THE TRUSTEE PRIOR TO THE
CLOSE OF BUSINESS ON AUGUST 19, 2016.
IF A RESPONSE IS FILED, A HEARING WILL BE HELD WITH NOTICE ONLY TO
THE OBJECTING PARTY. IF NO HEARING ON THIS MOTION IS TIMELY
REQUESTED, THE RELIEF REQUESTED SHALL BE DEEMED TO BE
UNOPPOSED, AND THE COURT MAY ENTER AN ORDER GRANTING THE
RELIEF SOUGHT OR PERMITTING THE NOTICED ACTION TO BE TAKEN.
Case 09-33918-hdh11 Doc 1060 Filed 07/25/16 Entered 07/25/16 14:51:11 Page 1 of 8
2. _____________________________________________________________________________________________
MOTION FOR ORDER APPROVING COMPROMISE AND SETTLEMENT AGREEMENT
BETWEEN THE TRUSTEE AND WILLIAM MAXWELL, WILLIAM MAXWELL, PLLC, AND
WILLIAM MAXWELL, PC Page 2 of 5
#4819-2741-0481
TO THE HONORABLE HARLIN D. HALE,
UNITED STATES BANKRUPTCY JUDGE:
COMES NOW Matthew D. Orwig, the duly-appointed Chapter 11 Trustee and
Liquidating Trustee of the FirstPlus Financial Group, Inc. bankruptcy estate (the “Trustee”)
seeking this Court’s approval for the settlement and compromise of controversies between the
Trustee and William Maxwell, William Maxwell, PLLC, and William Maxwell, PC
(collectively, “William Maxwell”) (collectively, the “Parties”). In support of this motion, which
is made pursuant to Bankruptcy Rule 9019, the Trustee would show the Court the following:
JURISDICTION AND VENUE
1. This Court has jurisdiction over the subject matter of this Motion pursuant to 28
U.S.C. § 1334(b) and the standing order of reference of the District Court. This matter is a core
proceeding. 28 U.S.C. § 157(b)(1), (b)(2)(O).
2. Venue in this Court is proper under 28 U.S.C. §§ 1408 and 1409.
BACKGROUND FACTS
3. The Debtor filed for relief under Chapter 11 of the United States Bankruptcy
Code on June 23, 2009. The Trustee was appointed on July 24, 2009.
4. No creditors’ committee was appointed in this case by the United States Trustee.
5. William Maxwell filed proofs of claim numbered 193-1, 195-5, and 196-1 against
the Estate in the total amount of $5,500,000.00 (the “Claims”) in which William Maxwell
asserted that he was owed that amount for unpaid compensation pursuant to a Legal Services
Agreement and bonus compensation
6. As alleged in the Trustee’s First Amended Complaint in the adversary proceeding
styled Orwig v. Freeman, et al., Adversary No. 11-03397-hdh, pending in this Court (the
Case 09-33918-hdh11 Doc 1060 Filed 07/25/16 Entered 07/25/16 14:51:11 Page 2 of 8
3. _____________________________________________________________________________________________
MOTION FOR ORDER APPROVING COMPROMISE AND SETTLEMENT AGREEMENT
BETWEEN THE TRUSTEE AND WILLIAM MAXWELL, WILLIAM MAXWELL, PLLC, AND
WILLIAM MAXWELL, PC Page 3 of 5
#4819-2741-0481
“Adversary Proceeding”), William Maxwell served as Debtor’s Counsel and participated in the
wrongdoing made the basis of the lawsuit.
7. The Trustee and William Maxwell have agreed upon terms for settlement of the
Claim and the Adversary Proceeding. A copy of the Compromise and Settlement Agreement
(the “Agreement”) is attached to this motion as Exhibit A, and is incorporated herein by
reference. The Agreement is a walk-away providing that William Maxwell will withdraw his
$5.5 million in proofs of claim and his counterclaim and that the Trustee will drop his claims
pleaded against William Maxwell. The Agreement provides for a full release of any and all pre-
and post-petition claims and causes of action between the Parties.
8. Because the controversies between the Parties involve issues that would likely
take substantial time and money to resolve, the Trustee has concluded that the interests of the
estate are better served by entering into the attached Agreement. The Trustee requests approval
to enter into the Agreement as follows.
BASIS FOR RELIEF REQUESTED
9. In deciding whether to approve a proposed settlement agreement or compromise
of controversy, a bankruptcy court should consider the following factors:
a. the probability of success on the merits and the resolution of the dispute;
b. the complexity of the litigation being settled;
c. the expense, inconvenience and delay associated with litigating the dispute; and
d. the paramount interests of creditors.
Texas Extrusion Corp. v. Lockheed Corp. (In re Texas Extrusion Corp.), 844 F.2d 1142,
1158-59 (5th Cir. 1988), cert denied, 105 S. Ct. 31 (1989); United States v. Aweco, Inc. (In re
Aweco, Inc.), 752 F.2d 293, 298 (5th Cir. 1984), cert. denied, 469 U.S. 880 (1984).
Case 09-33918-hdh11 Doc 1060 Filed 07/25/16 Entered 07/25/16 14:51:11 Page 3 of 8
4. _____________________________________________________________________________________________
MOTION FOR ORDER APPROVING COMPROMISE AND SETTLEMENT AGREEMENT
BETWEEN THE TRUSTEE AND WILLIAM MAXWELL, WILLIAM MAXWELL, PLLC, AND
WILLIAM MAXWELL, PC Page 4 of 5
#4819-2741-0481
10. While it is necessary for the proponent of a compromise to set forth the factual
and legal basis for the compromise so the court can make an intelligent and informed evaluation
of the proposed settlement, it is not incumbent upon the proponent to present a mini-trial or a full
evidentiary hearing. Texas Extrusion, 844 F.2d at 1158-59; Aweco, 725 F.2d at 298.
11. The Agreement is in the best interests of the Debtor’s bankruptcy estate and
should be approved. The Settlement provides for William Maxwell to withdraw his proofs of
claim for $5.5 million while the Trustee dismisses his claims against William Maxwell. While
the Trustee believes that he has a strong claims against William Maxwell, the Trustee is
concerned that, even if he is ultimately successful in prosecuting his claims, there are insufficient
collectable assets to justify the prosecution, particularly in light of the forfeiture order entered
against William Maxwell after William Maxwell’s conviction in the related criminal
proceedings. Given the cost of prosecuting the Trustee’s claim, the Trustee believes that
William Maxwell’s agreement to withdraw his claim in exchange for the Trustee doing the same
is in the best interests of the estate. Accordingly, the Trustee requests that the Court grant this
motion and authorize the Trustee and William Maxwell to enter into the Agreement.
WHEREFORE, the Trustee respectfully requests that this Court find that the
Agreement incorporated as Exhibit A is in the best interest of the Debtor’s estate and approve
of the Agreement between the Trustee and William Maxwell, William Maxwell, PLLC, and
William Maxwell, PC.
Case 09-33918-hdh11 Doc 1060 Filed 07/25/16 Entered 07/25/16 14:51:11 Page 4 of 8
5. _____________________________________________________________________________________________
MOTION FOR ORDER APPROVING COMPROMISE AND SETTLEMENT AGREEMENT
BETWEEN THE TRUSTEE AND WILLIAM MAXWELL, WILLIAM MAXWELL, PLLC, AND
WILLIAM MAXWELL, PC Page 5 of 5
#4819-2741-0481
Date: July 25, 2016 Respectfully submitted,
/s/ John Volney
Eric W. Pinker, P.C. (epinker@lynnllp.com)
Texas Bar No. 16016550
John Volney (jvolney@lynnllp.com)
Texas Bar No. 24003118
LYNN PINKER COX & HURST, LLP
2100 Ross Avenue, Suite 2700
Dallas, Texas 75201
(214) 981-3800 Telephone
(214) 981-3839 Facsimile
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the above and foregoing
document has been served on July 25, 2016 via ECF or United States Mail to the parties of
record.
/s/ John Volney
John Volney
Case 09-33918-hdh11 Doc 1060 Filed 07/25/16 Entered 07/25/16 14:51:11 Page 5 of 8