[db7]

https://www.kccllc.net/medley/document/2110526210917000000000001


Proposed Chapter 11
Recovery Estimate $
Low High
$ 3,066,023 $ 4,344,065


in another ~6months or so I guess we'll see how close these projections were...............

[db7]

skimming this old document, wonder how much of this still exists or came to pass:
https://www.kccllc.net/medley/document/2110526210706000000000003

"

F. Retention Plan
By and through the Combined Disclosure Statement and Plan, the Debtor’s interest in
proceeds from the Remaining Company Contracts will be assigned to the Liquidating Trust and
the Debtor expects that the net proceeds of the Remaining Company Contracts will provide a
significant recovery to Allowed Claims. Specifically, and as more fully set in the liquidation
analysis attached hereto as Exhibit A, the Debtor expects that expects that, for the period ending
ending March 31, 2022, the Remaining Company Contracts will generate approximately
$1,725,000 of profit, which will be upstreamed to the Debtor. Such revenue is,, subject to the
continuation of the Remaining Company Contracts, the most financially significant of which is an
investment advisory agreement between Sierra and SIC Advisors LLC, which the Debtor expects
to continue through at least December 31, 2021, subject to further extension.13
As of July 6, 2021,
13 The Debtor anticipates that Sierra’s contract will terminate on December 31, 2021, subject to further extensions to
permit Sierra Income Corporation to extend the termination date until February 28, 2022. As set forth in the Sierra
IMA and required by the SEC of all IMAs of this type, the agreement may be terminated at any time, without the
Case 21-10526-KBO Doc 244 Filed 07/06/21 Page 54 of 82
-49-
12957744.v3
the Debtor’s subsidiaries are also currently holding approximately $3,741,806 on account of the
Remaining Company Contracts, which they are entitled to upstream to the Debtor upon completion
of the Remaining Company Contracts. Absent continuation, of the Remaining Company
Contracts, the Debtor expects that the clients will seek the return of some or all of those funds.
The Debtor therefore expects that the net proceeds of the Remaining Company Contracts will
provide a significant recovery for Allowed Claims.

"

[Enterprising Investor]

Order Granting Medley LLC Liquidating Trust’s Motion Pursuant Federal Rule 2019 to Approve Settlement with Eversheds Sutherland (US) LLP (11/09/23)

No objection filed. As a result, the hearing scheduled for 11/14/23 is no longer necessary.

http://www.kccllc.net/medley/document/2110526231109000000000002

[db7]

We're due the Post Confirmation Report for period ending 9/30 'soon'... The more I go through the last report and all events that have transpired, I think our recovery (or lack thereof) here is purely based on the results of the Allianz Tower outcome.

$0 to $1 possible(?)

Trading was around $0.50 on both pfd's if I recall correctly prior to trading halts...

[db7]

.. and now we know what the 11/14 hearing was/is about......

[db7]

"Eversheds agrees to make a formal written demand against the
Debtor’s insurers on or before October 20, 2023. In the event that
demand does not lead to a resolution between Eversheds and the
Debtor’s insurers, Eversheds agrees it will file a lawsuit to collect
from the Debtor’s insurers on or before March 29, 2024. "


"
Notwithstanding the Credit set forth above, to the extent the Liquidating Trust is closed prior to the Insurance Lawsuit being finally resolved, the Liquidating Trust shall pay the Revised Final Fee Award to Eversheds, and the Credit will be forfeited by the Liquidating Trust.
"

[db7]

excellent: "The Settlement Agreement reduces Eversheds’ Final Fee Award (as defined
below) from $2,080,055.19 to $436,673.28, and Eversheds shall seek payment of its legal fees
from the Debtor’s insurance companies. To the extent Eversheds receives payment for its legal
fees from any insurance company, the Liquidating Trust will receive a dollar-for-dollar credit
against the $436,673.28 for every dollar Eversheds recovers. "

https://www.kccllc.net/medley/document/2110526231026000000000002

[db7]

curious what the matters scheduled are for this 11/14 omnibus hearing or if it's just a placeholder that will be rescheduled:

https://www.kccllc.net/medley/document/2110526231026000000000001

ORDER SCHEDULING OMNIBUS HEARING DATE
Pursuant to Del. Bankr. L.R. 2002-1(a), the Court has scheduled the following omnibus
hearing date in the above-captioned case:
Date & Time Location
November 14, 2023 at 3:00 p.m. (ET) U.S. Bankruptcy Court for the District of Delaware
824 North Market Street, 6th Floor, Courtroom No. 3
Wilmington, Delaware 19801

[db7]

was hoping so; fingers crossed it's 'quick'

[Enterprising Investor]

Some disputes may be resolved through arbitration.

[db7]

does anyone know if a case exists of liquidating trust vs allianz tower at this time?

[db7]

well if they spent 1,000 hours to get the 'easier' $6.7mil, don't see how there will be anything left from that pool OR from the $6.4mil that is expected to be harder to get and 'discounted?' (and may take as many hours?)

are we at the point where this should just be wrapped up?

are we looking at 'anything' being left for us? maybe $1-$2mil?

just thinking aloud...................... thank God for the SEC's $10mil!

[db7]

they settled? https://www.kccllc.net/medley/document/2110526230927000000000002


"

Status: The Liquidating Trust and Eversheds Sutherland (US) LLP have reached a
settlement regarding this matter. Accordingly, a hearing on this matter is no
longer necessary

"

[db7]

seems like we have a very strong argument here imo: https://www.kccllc.net/medley/document/2110526230918000000000001

[FrancisD]

Thanks for your detailed and clear explanation.

[Renee]

All bankruptcy stocks are allowed to trade until a Bankruptcy Judge cancels the equity, either in a Chapter 11 Reorganization or a Chapter 7 Liquidation. In rare instances the BK Judge approves a reverse split of the equity (stock) instead of cancelling the equity.

In some cases the SEC may revoke a company's stock registration(s) if the company is severely delinquent in filing Financials, in which case(s) the stock would no longer be able to trade on any public forum.....but the stock would still exist unless/until a Bankruptcy Judge cancels the equity/stock.

Medley Management Inc. is current in their Financial reporting obligations so it is not likely the SEC will get involved.

[FrancisD]

Hello, Sir, please, I am wondering if you have known why this ticker was resumed to trade in the market. It will be highly appreciated if you could provide a clue.

[db7]

https://www.kccllc.net/medley/document/2110526230721000000000001

[db7]

"NOTICE OF AGENDA OF MATTERS SCHEDULED
FOR HEARING ON JUNE 21, 2023 AT 9:00 A.M. (ET)
THIS HEARING HAS BEEN ADJOURNED TO AUGUST 15, 2023
AT 9:30 A.M. (ET) WITH PERMISSION FROM THE COURT.
"

[db7]

Court Docket: #0650

Document Name: Notice of Agenda of Matters Scheduled for Hearing on May 24, 2023 at 10:30 a.m. (ET) [HEARING RESCHEDULED. Hearing Originally Scheduled for 5/24/2023 at 10:30 AM has been rescheduled. Hearing scheduled for 6/21/2023 at 09:00 AM at US Bankruptcy Court, 824 Market St., 6th Fl., Courtroom #3, Wilmington, Delaware.] (Filed by Liquidating Trust)

[db7]

https://www.kccllc.net/medley/document/2110526230418000000000001

[db7]

i'm usually happy on bk plays when i breakeven lol; so yes, very appreciative of what they accomplished here!

[freddie me]

Pros say you already got more than expected lol

[db7]

really hoping they drop us another interim distribution in lieu of receiving the $6.7mil

[freddie me]

I expect $6.7 settlement to be heavily nicked for fees
and Allianz cash to be long-time coming, and at a discount

[db7]

"
2. Effective Date. This Assignment shall become effective on the date (the “Effective
Date”) all of the following conditions have been satisfied: (a) all of the Settling Parties have
executed this Assignment; and (b) either (i) at least $7.5 million in insurance proceeds have been
paid out from those Policies listed under “Tower 3 (E&O)” in Schedule II or (ii) the Medley D&Os
have executed a release of the insurance companies that issued the Policies listed under “Tower 3
(E&O)” in Schedule II in connection with those insurance companies’ funding some or all of a
settlement of the Pre-April 30 Claims.
3. Expiration Date. If the Effective Date does not occur prior to July 1, 2023, this
Assignment becomes null and void, and neither this Assignment nor evidence of its terms shall be
admissible for any purpose in any action or proceeding.7

"

[db7]

speaking of: "counsel for the Liquidating Trust and the Settling Insiders have collectively
spent more than 1000 hours working on and negotiating the Settlement Agreements’ various terms"

[db7]

"Here, on the other hand, Exhibit C includes an
assignment mechanism that would allow the Liquidating Trust to initiate litigation against the
Allianz Tower in the coming weeks. "

[vpagano]

Motion granted for settlement, details:

http://www.kccllc.net/medley/document/2110526230222000000000003

[db7]

https://www.kccllc.net/medley/document/2110526230321000000000001

[db7]

thank you sir!

[Enterprising Investor]

Medley LLC Liquidating Trust's Motion Pursuant to 11 U.S.C. § 105(a) and Federal Rule of Bankruptcy Procedure 9019 to Approve Settlement with Certain Former Insiders of the Debtor

Hearing scheduled for 3/23/2023 at 01:00 PM at US Bankruptcy Court, 824 Market St., 6th Fl., Courtroom #3, Wilmington, Delaware.

Objections due by 3/8/2023.

None filed.

[freddie me]

#629**COMPLAINT TO AVOID AND RECOVER TRANSFERS
http://www.kccllc.net/medley/document/2110526230306000000000001

[freddie me]

*COMPLAINT TO AVOID AND RECOVER TRANSFERS
http://www.kccllc.net/medley/document/2110526230303000000000001

25. During the Preference Period, the Debtor made five transfers (each, a “Transfer”and collectively, the “Transfers”) totaling $2,015,986.53 to Defendant

[freddie me]

Could be also ZERO (short or even long term)

I dont know what liability side / fees of Trust looks like at this point
It wouldnt surprise me if those "wind-down funds" were fairy dust

[db7]

‘I think’

[freddie me]

So w $2mm add'l ***$3.55? or so "target?"

Dont get me wrong, in no way do i assume these numbers anything more than a rough guess

[db7]

weren't we expecting ~$2mil 'just' from business winddown? Prior to any liquidating trustee 'extra' actions?

[freddie me]

So ***$3.14? $6.7m pre4/30+$6.4m post4/30+$2.3mEvershed =($15.4/5) *1.02

Assuming $1.02 / $5 million payout based on SEC

[db7]

$1.70-$3.50??? $2mil biz completion. $1-$2mil lawyer withhold/clawback? Then today’s settlement low side vs high side.

????

[freddie me]

Can anybody help the slow kids w recovery math?

[db7]

vpagano, thank you for posting!

[vpagano]

Settlement Agreement:

http://www.kccllc.net/medley/document/2110526230222000000000003

[db7]

https://www.kccllc.net/medley/document/2110526230213000000000001

[freddie me]

Medley Seeks Ch. 11 Block On Final Eversheds Fee Bill
By Carolina Bolado

Law360 (January 24, 2023, 4:13 PM EST) -- A liquidation trustee for bankrupt asset manager Medley LLC asked a Delaware bankruptcy judge on Monday to vacate the final fee application by special counsel Eversheds Sutherland LLP for allegedly misrepresenting...

https://www.law360.com/articles/1568651/medley-seeks-ch-11-block-on-final-eversheds-fee-bill

[freddie me]

MOTION TO VACATE ORDER RETAINING, FEE APPLICATION EVERSHEDS SUTHERLAND
http://www.kccllc.net/medley/document/2110526230123000000000002

[db7]

https://www.kccllc.net/medley/document/2110526230119000000000002

[db7]

Latest update as of 11/15 in the NY State court: https://iapps.courts.state.ny.us/nyscef/ViewDocument?docIndex=qkoGiXqAUKjcHkEzV9OQ8A==

[Enterprising Investor]

General Bar Date was 4/30/21 at 5:00 ET

The General Bar Date specifically excludes any claims derived from, or based upon, the 2024 Notes (3) and 2026 Notes (4), or the Notes Indentures (5). Except as otherwise provided herein, the General Bar Date will apply to all claims of any kind that arose, or are deemed to have arisen, prior to March 7, 2021 (the “Petition Date”), the date on which the Debtor commenced its case under chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”), including, but not limited to administrative expense claims under section 503(b)(9) of the Bankruptcy Code and all claims of setoff or recoupment. For the avoidance of doubt, the General Bar Date established by the Bar Date Order supersedes any prior notice of a different bar date or deadline for filing proofs of claim, whether posted on the Court’s docket or otherwise.

http://www.kccllc.net/medley/document/2110526210326000000000004