EKEJIJA- NVC FUND-SEC SETTLEMENT SOLUTION
CASE: 2:20-cv-08985-ODW-DFM
Case No.: 2:20-cv-08985-FWS-DFM
Dear John F. Libby,
As requested by Judge Fred W. Slaughter, the undersigned, frank-ojogwa: Ekejija, comes now to submit in good faith for your favorable consideration a graceful workable solution to settle and resolve the above-referenced egregious case (the “Case”), according to the requirement of Rule 1 of the Federal Rules of Civil Procedure (“FRCP”), that “all civil actions and proceedings in the United States district courts … be construed, administered, and employed by the court and the parties to secure the just, speedy, and inexpensive determination of every action and proceeding.”
The purpose of my proposal is to achieve the complete, final, fair, and equitable resolution of all of the financial, civil rights, and reputational damages and other civil claims I am holding against the U.S. Securities and Exchange Commission, an agency of the federal government (the “SEC”), arising out of and suffered in connection with the extreme quantifiable and unquantifiable economic and wrongs, injuries, damages, defamations, prejudices, and injustices done to our companies and me, by the SEC’s egregious, willful, wrongful, meritless, reckless, abusive, and vindictive crusade, undertaken under color of law and constitutes a gross breach of fidelity, over the past 11 years. That the SEC persisted in misusing and abusing its government authority, compounding these many wrongs long after it knew or should have known that its allegations were meritless, and the resulting compounding of its wrongful behavior, and that such conduct exposed the SEC and the federal government to ridicules, substantial financial and other liability, makes the situation even more outrageous.
Notwithstanding the foregoing, I am willing to settle and resolve this matter upon the terms and conditions summarized below. You will see that my proposal satisfies each of the requirements of FRCP Rule 1. Indeed, I am proposing to achieve the intended result by underwriting the financial elements of my claims out of our assets and at no cost to the government. Moreover, the structure and mechanisms of this proposal are eminently fair and reasonable by design and within your authority as a federal judge to implement.
EKEJIJA- NVC FUND-SEC SETTLEMENT SOLUTION
CASE: 2:20-cv-08985-ODW-DFM
Case No.: 2:20-cv-08985-FWS-DFM
Dear John F. Libby,
As requested by Judge Fred W. Slaughter, the undersigned, frank-ojogwa: Ekejija, comes now to submit in good faith for your favorable consideration a graceful workable solution to settle and resolve the above-referenced egregious case (the “Case”), according to the requirement of Rule 1 of the Federal Rules of Civil Procedure (“FRCP”), that “all civil actions and proceedings in the United States district courts … be construed, administered, and employed by the court and the parties to secure the just, speedy, and inexpensive determination of every action and proceeding.”
The purpose of my proposal is to achieve the complete, final, fair, and equitable resolution of all of the financial, civil rights, and reputational damages and other civil claims I am holding against the U.S. Securities and Exchange Commission, an agency of the federal government (the “SEC”), arising out of and suffered in connection with the extreme quantifiable and unquantifiable economic and wrongs, injuries, damages, defamations, prejudices, and injustices done to our companies and me, by the SEC’s egregious, willful, wrongful, meritless, reckless, abusive, and vindictive crusade, undertaken under color of law and constitutes a gross breach of fidelity, over the past 11 years. That the SEC persisted in misusing and abusing its government authority, compounding these many wrongs long after it knew or should have known that its allegations were meritless, and the resulting compounding of its wrongful behavior, and that such conduct exposed the SEC and the federal government to ridicules, substantial financial and other liability, makes the situation even more outrageous.
Notwithstanding the foregoing, I am willing to settle and resolve this matter upon the terms and conditions summarized below. You will see that my proposal satisfies each of the requirements of FRCP Rule 1. Indeed, I am proposing to achieve the intended result by underwriting the financial elements of my claims out of our assets and at no cost to the government. Moreover, the structure and mechanisms of this proposal are eminently fair and reasonable by design and within your authority as a federal judge to implement.
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Doc1065 william maxwell settlement_signed by the judge
1. 1
#4810-5486-4177
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
In re: § Chapter 11
§
FIRSTPLUS FINANCIAL GROUP, INC., § Case No. 09-33918-HDH
§
Debtor. §
ORDER APPROVING COMPROMISE AND SETTLEMENT AGREEMENT
BETWEEN THE TRUSTEE AND WILLIAM MAXWELL, WILLIAM MAXWELL,
PLLC, AND WILLIAM MAXWELL, PC
Came on for consideration the Motion [docket 1060] (the “Motion”) of Matthew D.
Orwig, the Liquidating Trustee (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 (the “Agreement”). The Court, having considered the Motion,
the Agreement, proper service thereof, and any evidence and arguments presented in support of
Signed September 7, 2016
______________________________________________________________________
The following constitutes the ruling of the court and has the force and effect therein described.
United States Bankruptcy Judge
Case 09-33918-hdh11 Doc 1065 Filed 09/08/16 Entered 09/08/16 11:51:49 Page 1 of 2
2. 2
#4810-5486-4177
the Motion and Agreement, finds that the Agreement is in the best interest of the Debtor’s estate.
The Motion is therefore well-taken and shall be, and hereby is, GRANTED. It is therefore,
ORDERED that the Agreement between the Trustee and William Maxwell, William
Maxwell, PLLC, and William Maxwell, PC is approved in the form described in and attached to
the Motion in all respects; and it is further
ORDERED that the Trustee is authorized to enter into this Agreement.
### END OF ORDER###
Submitted by:
John Volney
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
jvolney@lynnllp.com
Counsel for Matthew D. Orwig,
the Chapter 11 Trustee and Liquidating Trustee
for the Estate of FirstPlus Financial Group, Inc.
4810-5486-4177, v. 1
Case 09-33918-hdh11 Doc 1065 Filed 09/08/16 Entered 09/08/16 11:51:49 Page 2 of 2