Medley Management Inc. (MDLM)

[db7]

https://www.kccllc.net/medley/document/2110526240419000000000001

[db7]

23-50121-KBO Medley LLC Liquidating Trust et al v. Eversheds Sutherland (US) LLP et al.. Is 'this' case different than the Evershed's settlement agreement from last October?

[db7]

23-50138-KBO Medley LLC Liquidating Trust v. RSM US LLP.. last document filed was that the appointed mediator had a potential conflict of interest; assuming we're waiting on a new one

this is try to get back ~$300k from RSM of invoices paid after they should have been(?)

[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. "

Of interest(?), I cannot locate any litigation involving Eversheds on Pacer.........

[db7]

https://www.kccllc.net/medley/document/2110526240405000000000001

[db7]

https://www.kccllc.net/medley/document/2110526240404000000000001

[db7]

https://www.kccllc.net/medley/document/2110526240327000000000001 let's hope they're not too limited:

"
Entry of both the Protective Order and the Production Order is necessary to
allow the Liquidating Trust to comply with the subpoena in a cost-efficient manner, in order to
preserve the Liquidating Trust’s extremely limited financial resources
"

[db7]

https://www.kccllc.net/medley/document/2110526240322000000000001

[db7]

last doc i see regarding this is: https://www.kccllc.net/medley/document/2110526230727000000000001

[db7]

assuming this is related to: "Liquidating Trust’s Request for Documents and Information" (???)

[db7]

i 'thought' everything was behind us with Eversheds(?)

[db7]

ugh, it 'is' more Eversheds: Court Docket: #0695

Document Name: Notice of Service of William E. Chipman, Jr. re: Defendant's Initial Disclosures Pursuant to Fed. R. Civ. P. 26(a)(1) and Fed. R. Bankr. P. 7026 (Filed by Eversheds Sutherland (US) LLP)

[db7]

sooo... Allianz Tower update 'or' Eversheds crediting monies... must be the former or why bring in lawyer... excited to hear the outcome.. fingers crossed!

[db7]

april 3rd omnibus hearing; https://www.kccllc.net/medley/document/2110526240312000000000001

[db7]

https://www.kccllc.net/medley/document/2110526240305000000000001

[db7]

https://www.kelleydrye.com/people/richard-gage

[db7]

https://www.kccllc.net/medley/document/2110526240304000000000001

[db7]

last one didn't tie-out either so I'm assuming my understanding that it should equals A + B + C is incorrect and obviously there must be disbursements made that don't need to appear on this sheet(?)

[db7]

something doesn't add up in this Post-confirmation report(?) Total Disbursements during period are listed as: $1,121,655.83 which is supposed to be made up of:
a (professional fees and expenses (bankruptcy)) + b (professional fees and expenses (non-bankruptcy)) + c (All professional fees and expenses)

in 'this' document we see:
a Paid Current Quarter at: $2,522,415 (I believe this is a mistake that was inadvertently copied from the last Post-confirmation filing and should actually be $0?)
b Paid Current Quarter at: $118,755
c Paid Current Quarter at: $0

So, 'if' I'm understanding this correctly the Total Disbursements during this period should be either:
$2,522,415 + $118,755 = $2,641,170
OR
$118,755

So how/why do we see: $1,121,655.83

What am I missing here?

[db7]

Post-Confirmation Report for Medley LLC for the Quarter Ending December 31, 2023 (Filed by Liquidating Trust)

well lawyers all made whole on due amounts:

https://www.kccllc.net/medley/document/2110526240118000000000001

[db7]

https://www.kccllc.net/medley/document/2110526240102000000000001

[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