Disputed ownership funds liquidating trust

Sibbet of American Express Financial Corporation, Thomas Thompson of Chanin Capital Partners and Stephanie Parker of JPMorgan Chase.The Trustee and Trust Committee adopted a technical amendment to the Trust Agreement as follows: to provide the official name of the Trust as "Crown Paper Liquidating Trust" and to amend Section 3.2(a) of the Trust Agreement to provide that the commencement of litigation proceedings would not require approval of the Trust Committee.claims for avoidance of pre-bankruptcy payments and other transfers believed to be preferential or fraudulent under applicable bankruptcy law (�Preference Claims�); and claims against various parties arising out of the creation and/or separation of the Crown Entities from their previous ownership and their subsequent operation, accounting and other activities (�Spin-off Claims�).Pursuant to the Plan, the holders of Beneficial Interests arising from shares are not entitled to receive any distributions until holders of Beneficial Interests arising from pre-bankruptcy creditor claims, including the publicly traded bonds, are paid in full.The Crown Entities did, during their chapter 11 cases, file and resolve objections to certain claims as to which priority or secured status was asserted.The obligations assumed by the Trust include: the payment (from reserves established on the Effective Date) or settlement of disputed unpaid chapter 11 administrative and other priority claims against the Crown Entities (�Disputed Priority Claims�); the payment (for which there are no reserves) or settlement of certain unpaid chapter 11 administrative claims against the Crown Entities and post confirmation, pre-Effective Date fees and expenses of professionals of the Crown Entities, which are anticipated to exceed million (�Deferred Administrative Expenses�); the payment of remaining installments or in lump sum of certain tax obligations of the Crown Entities that were to be paid after the Effective Date pursuant to the Plan which were estimated to be between

Sibbet of American Express Financial Corporation, Thomas Thompson of Chanin Capital Partners and Stephanie Parker of JPMorgan Chase.The Trustee and Trust Committee adopted a technical amendment to the Trust Agreement as follows: to provide the official name of the Trust as "Crown Paper Liquidating Trust" and to amend Section 3.2(a) of the Trust Agreement to provide that the commencement of litigation proceedings would not require approval of the Trust Committee.claims for avoidance of pre-bankruptcy payments and other transfers believed to be preferential or fraudulent under applicable bankruptcy law (�Preference Claims�); and claims against various parties arising out of the creation and/or separation of the Crown Entities from their previous ownership and their subsequent operation, accounting and other activities (�Spin-off Claims�).Pursuant to the Plan, the holders of Beneficial Interests arising from shares are not entitled to receive any distributions until holders of Beneficial Interests arising from pre-bankruptcy creditor claims, including the publicly traded bonds, are paid in full.The Crown Entities did, during their chapter 11 cases, file and resolve objections to certain claims as to which priority or secured status was asserted.The obligations assumed by the Trust include: the payment (from reserves established on the Effective Date) or settlement of disputed unpaid chapter 11 administrative and other priority claims against the Crown Entities (�Disputed Priority Claims�); the payment (for which there are no reserves) or settlement of certain unpaid chapter 11 administrative claims against the Crown Entities and post confirmation, pre-Effective Date fees and expenses of professionals of the Crown Entities, which are anticipated to exceed $4 million (�Deferred Administrative Expenses�); the payment of remaining installments or in lump sum of certain tax obligations of the Crown Entities that were to be paid after the Effective Date pursuant to the Plan which were estimated to be between $1 million and $2 million (�Tax Claims�); the sharing of asset liquidation and litigation proceeds with certain banks and other lenders pursuant to agreements between the Crown Entities and such lenders in a formula approved by the Court and incorporated in the Plan (�Lenders� Share�); and operating, litigation and professional expenses of the Trust (�Trust Expenses�).The Lenders' Share is a formula of proceeds of most assets transferred into the Trust.However, the Crown Entities did not file or resolve objections with respect to pre-bankruptcy, non-priority claims of creditors.The Plan provides that the filing of objections to such claims is only required to take place upon the Trust having over $1 million of available cash to be distributed to holders of Beneficial Interests in the Trust.t is estimated as of January 31, 2003, that the Trust must generate more than $18 million in recoveries on Preference Claims and/or Spin-off Claims before there will be $1 million of Available Cash to trigger the claims review process and a potential distribution to holders of Beneficial Interests in the Trust.

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Sibbet of American Express Financial Corporation, Thomas Thompson of Chanin Capital Partners and Stephanie Parker of JPMorgan Chase.

The Trustee and Trust Committee adopted a technical amendment to the Trust Agreement as follows: to provide the official name of the Trust as "Crown Paper Liquidating Trust" and to amend Section 3.2(a) of the Trust Agreement to provide that the commencement of litigation proceedings would not require approval of the Trust Committee.claims for avoidance of pre-bankruptcy payments and other transfers believed to be preferential or fraudulent under applicable bankruptcy law (�Preference Claims�); and claims against various parties arising out of the creation and/or separation of the Crown Entities from their previous ownership and their subsequent operation, accounting and other activities (�Spin-off Claims�).

Pursuant to the Plan, the holders of Beneficial Interests arising from shares are not entitled to receive any distributions until holders of Beneficial Interests arising from pre-bankruptcy creditor claims, including the publicly traded bonds, are paid in full.

The Crown Entities did, during their chapter 11 cases, file and resolve objections to certain claims as to which priority or secured status was asserted.

The obligations assumed by the Trust include: the payment (from reserves established on the Effective Date) or settlement of disputed unpaid chapter 11 administrative and other priority claims against the Crown Entities (�Disputed Priority Claims�); the payment (for which there are no reserves) or settlement of certain unpaid chapter 11 administrative claims against the Crown Entities and post confirmation, pre-Effective Date fees and expenses of professionals of the Crown Entities, which are anticipated to exceed $4 million (�Deferred Administrative Expenses�); the payment of remaining installments or in lump sum of certain tax obligations of the Crown Entities that were to be paid after the Effective Date pursuant to the Plan which were estimated to be between $1 million and $2 million (�Tax Claims�); the sharing of asset liquidation and litigation proceeds with certain banks and other lenders pursuant to agreements between the Crown Entities and such lenders in a formula approved by the Court and incorporated in the Plan (�Lenders� Share�); and operating, litigation and professional expenses of the Trust (�Trust Expenses�).

million and million (�Tax Claims�); the sharing of asset liquidation and litigation proceeds with certain banks and other lenders pursuant to agreements between the Crown Entities and such lenders in a formula approved by the Court and incorporated in the Plan (�Lenders� Share�); and operating, litigation and professional expenses of the Trust (�Trust Expenses�).The Lenders' Share is a formula of proceeds of most assets transferred into the Trust.However, the Crown Entities did not file or resolve objections with respect to pre-bankruptcy, non-priority claims of creditors.The Plan provides that the filing of objections to such claims is only required to take place upon the Trust having over

Sibbet of American Express Financial Corporation, Thomas Thompson of Chanin Capital Partners and Stephanie Parker of JPMorgan Chase.The Trustee and Trust Committee adopted a technical amendment to the Trust Agreement as follows: to provide the official name of the Trust as "Crown Paper Liquidating Trust" and to amend Section 3.2(a) of the Trust Agreement to provide that the commencement of litigation proceedings would not require approval of the Trust Committee.claims for avoidance of pre-bankruptcy payments and other transfers believed to be preferential or fraudulent under applicable bankruptcy law (�Preference Claims�); and claims against various parties arising out of the creation and/or separation of the Crown Entities from their previous ownership and their subsequent operation, accounting and other activities (�Spin-off Claims�).Pursuant to the Plan, the holders of Beneficial Interests arising from shares are not entitled to receive any distributions until holders of Beneficial Interests arising from pre-bankruptcy creditor claims, including the publicly traded bonds, are paid in full.The Crown Entities did, during their chapter 11 cases, file and resolve objections to certain claims as to which priority or secured status was asserted.The obligations assumed by the Trust include: the payment (from reserves established on the Effective Date) or settlement of disputed unpaid chapter 11 administrative and other priority claims against the Crown Entities (�Disputed Priority Claims�); the payment (for which there are no reserves) or settlement of certain unpaid chapter 11 administrative claims against the Crown Entities and post confirmation, pre-Effective Date fees and expenses of professionals of the Crown Entities, which are anticipated to exceed $4 million (�Deferred Administrative Expenses�); the payment of remaining installments or in lump sum of certain tax obligations of the Crown Entities that were to be paid after the Effective Date pursuant to the Plan which were estimated to be between $1 million and $2 million (�Tax Claims�); the sharing of asset liquidation and litigation proceeds with certain banks and other lenders pursuant to agreements between the Crown Entities and such lenders in a formula approved by the Court and incorporated in the Plan (�Lenders� Share�); and operating, litigation and professional expenses of the Trust (�Trust Expenses�).The Lenders' Share is a formula of proceeds of most assets transferred into the Trust.However, the Crown Entities did not file or resolve objections with respect to pre-bankruptcy, non-priority claims of creditors.The Plan provides that the filing of objections to such claims is only required to take place upon the Trust having over $1 million of available cash to be distributed to holders of Beneficial Interests in the Trust.t is estimated as of January 31, 2003, that the Trust must generate more than $18 million in recoveries on Preference Claims and/or Spin-off Claims before there will be $1 million of Available Cash to trigger the claims review process and a potential distribution to holders of Beneficial Interests in the Trust.

||

Sibbet of American Express Financial Corporation, Thomas Thompson of Chanin Capital Partners and Stephanie Parker of JPMorgan Chase.

The Trustee and Trust Committee adopted a technical amendment to the Trust Agreement as follows: to provide the official name of the Trust as "Crown Paper Liquidating Trust" and to amend Section 3.2(a) of the Trust Agreement to provide that the commencement of litigation proceedings would not require approval of the Trust Committee.claims for avoidance of pre-bankruptcy payments and other transfers believed to be preferential or fraudulent under applicable bankruptcy law (�Preference Claims�); and claims against various parties arising out of the creation and/or separation of the Crown Entities from their previous ownership and their subsequent operation, accounting and other activities (�Spin-off Claims�).

Pursuant to the Plan, the holders of Beneficial Interests arising from shares are not entitled to receive any distributions until holders of Beneficial Interests arising from pre-bankruptcy creditor claims, including the publicly traded bonds, are paid in full.

The Crown Entities did, during their chapter 11 cases, file and resolve objections to certain claims as to which priority or secured status was asserted.

The obligations assumed by the Trust include: the payment (from reserves established on the Effective Date) or settlement of disputed unpaid chapter 11 administrative and other priority claims against the Crown Entities (�Disputed Priority Claims�); the payment (for which there are no reserves) or settlement of certain unpaid chapter 11 administrative claims against the Crown Entities and post confirmation, pre-Effective Date fees and expenses of professionals of the Crown Entities, which are anticipated to exceed $4 million (�Deferred Administrative Expenses�); the payment of remaining installments or in lump sum of certain tax obligations of the Crown Entities that were to be paid after the Effective Date pursuant to the Plan which were estimated to be between $1 million and $2 million (�Tax Claims�); the sharing of asset liquidation and litigation proceeds with certain banks and other lenders pursuant to agreements between the Crown Entities and such lenders in a formula approved by the Court and incorporated in the Plan (�Lenders� Share�); and operating, litigation and professional expenses of the Trust (�Trust Expenses�).

million of available cash to be distributed to holders of Beneficial Interests in the Trust.t is estimated as of January 31, 2003, that the Trust must generate more than million in recoveries on Preference Claims and/or Spin-off Claims before there will be

Sibbet of American Express Financial Corporation, Thomas Thompson of Chanin Capital Partners and Stephanie Parker of JPMorgan Chase.The Trustee and Trust Committee adopted a technical amendment to the Trust Agreement as follows: to provide the official name of the Trust as "Crown Paper Liquidating Trust" and to amend Section 3.2(a) of the Trust Agreement to provide that the commencement of litigation proceedings would not require approval of the Trust Committee.claims for avoidance of pre-bankruptcy payments and other transfers believed to be preferential or fraudulent under applicable bankruptcy law (�Preference Claims�); and claims against various parties arising out of the creation and/or separation of the Crown Entities from their previous ownership and their subsequent operation, accounting and other activities (�Spin-off Claims�).Pursuant to the Plan, the holders of Beneficial Interests arising from shares are not entitled to receive any distributions until holders of Beneficial Interests arising from pre-bankruptcy creditor claims, including the publicly traded bonds, are paid in full.The Crown Entities did, during their chapter 11 cases, file and resolve objections to certain claims as to which priority or secured status was asserted.The obligations assumed by the Trust include: the payment (from reserves established on the Effective Date) or settlement of disputed unpaid chapter 11 administrative and other priority claims against the Crown Entities (�Disputed Priority Claims�); the payment (for which there are no reserves) or settlement of certain unpaid chapter 11 administrative claims against the Crown Entities and post confirmation, pre-Effective Date fees and expenses of professionals of the Crown Entities, which are anticipated to exceed $4 million (�Deferred Administrative Expenses�); the payment of remaining installments or in lump sum of certain tax obligations of the Crown Entities that were to be paid after the Effective Date pursuant to the Plan which were estimated to be between $1 million and $2 million (�Tax Claims�); the sharing of asset liquidation and litigation proceeds with certain banks and other lenders pursuant to agreements between the Crown Entities and such lenders in a formula approved by the Court and incorporated in the Plan (�Lenders� Share�); and operating, litigation and professional expenses of the Trust (�Trust Expenses�).The Lenders' Share is a formula of proceeds of most assets transferred into the Trust.However, the Crown Entities did not file or resolve objections with respect to pre-bankruptcy, non-priority claims of creditors.The Plan provides that the filing of objections to such claims is only required to take place upon the Trust having over $1 million of available cash to be distributed to holders of Beneficial Interests in the Trust.t is estimated as of January 31, 2003, that the Trust must generate more than $18 million in recoveries on Preference Claims and/or Spin-off Claims before there will be $1 million of Available Cash to trigger the claims review process and a potential distribution to holders of Beneficial Interests in the Trust.

||

Sibbet of American Express Financial Corporation, Thomas Thompson of Chanin Capital Partners and Stephanie Parker of JPMorgan Chase.

The Trustee and Trust Committee adopted a technical amendment to the Trust Agreement as follows: to provide the official name of the Trust as "Crown Paper Liquidating Trust" and to amend Section 3.2(a) of the Trust Agreement to provide that the commencement of litigation proceedings would not require approval of the Trust Committee.claims for avoidance of pre-bankruptcy payments and other transfers believed to be preferential or fraudulent under applicable bankruptcy law (�Preference Claims�); and claims against various parties arising out of the creation and/or separation of the Crown Entities from their previous ownership and their subsequent operation, accounting and other activities (�Spin-off Claims�).

Pursuant to the Plan, the holders of Beneficial Interests arising from shares are not entitled to receive any distributions until holders of Beneficial Interests arising from pre-bankruptcy creditor claims, including the publicly traded bonds, are paid in full.

The Crown Entities did, during their chapter 11 cases, file and resolve objections to certain claims as to which priority or secured status was asserted.

The obligations assumed by the Trust include: the payment (from reserves established on the Effective Date) or settlement of disputed unpaid chapter 11 administrative and other priority claims against the Crown Entities (�Disputed Priority Claims�); the payment (for which there are no reserves) or settlement of certain unpaid chapter 11 administrative claims against the Crown Entities and post confirmation, pre-Effective Date fees and expenses of professionals of the Crown Entities, which are anticipated to exceed $4 million (�Deferred Administrative Expenses�); the payment of remaining installments or in lump sum of certain tax obligations of the Crown Entities that were to be paid after the Effective Date pursuant to the Plan which were estimated to be between $1 million and $2 million (�Tax Claims�); the sharing of asset liquidation and litigation proceeds with certain banks and other lenders pursuant to agreements between the Crown Entities and such lenders in a formula approved by the Court and incorporated in the Plan (�Lenders� Share�); and operating, litigation and professional expenses of the Trust (�Trust Expenses�).

million of Available Cash to trigger the claims review process and a potential distribution to holders of Beneficial Interests in the Trust.

The Trust is the successor to all property interests and assumed responsibility for certain obligations of the Crown Entities as of March 1, 2002. The members of the Trust Committee for the Trust are: Peg A.The formula provides that the following share will be paid to the Lenders of proceeds of asset disposition or recovery: 100% of the first .3 million of net recoveries of Spin-off Claims; 0% of the first .3 million of gross recoveries from miscellaneous assets and Preference Claims; 50% of the recoveries over the first .3 million of such recoveries in both categories up to an aggregate of .3 million of proceeds; 30% of the recoveries over such .3 million of proceeds up to an aggregate of .3 million of proceeds; and 10% of all further recoveries over such .3 million of proceeds.The former publicly traded shares and bonds of Crown Vantage, Inc.At the date of the creation of the trust, litigation was pending involving the reversion of funds from one of the Crown Entities several retirement plans.This particular plan had funds in excess of those needed when Crown determined to terminate the plan and purchase a commercial annuity policy to provide required benefits to the retirement plan beneficiaries.

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