December 13, 2018 – Relativity Media and its Official Committee of Unsecured Creditors filed a Joint Liquidating Plan [Docket No. 633] and related Disclosure Statement [Docket No. 634]. The Disclosure Statement, which was approved on December 14, 2018 [Docket No. 636], states, “The Plan establishes the Liquidating Trust, which will, among other things, undertake the liquidation of the Debtors and their Estates, administer Distributions in accordance with the Plan and the Liquidating Trust Agreement and prosecute or otherwise resolve the Retained Causes of Action. The Plan Proponents believe that the Plan is in the best interest of the Debtors’ creditors and stakeholders.”
In a candid footnote as to the recovery potential for general unsecured claims, the Disclosure Statement notes, “The Liquidating Trustee would
need to bring in significant value through the prosecution of Retained Causes of Action to achieve anywhere near the higher end of the estimate.”
The following is an amended summary of classes, claims, voting rights and expected recoveries:
- Class 1 (“Secured Tax Claims”) is unimpaired, deemed to accept and not entitled to vote on the Plan. The estimated aggregate amount of claims is $0.00-$90,433.11 and the estimated recovery is 100%.
- Class 2 (“Other Secured Claims”) is unimpaired, deemed to accept and not entitled to vote on the Plan. The estimated aggregate amount of claims is $0.00 and the estimated recovery is 100%.
- Class 3 (“Other Priority Claims’) is unimpaired, deemed to accept and not entitled to vote on the Plan. The estimated aggregate amount of claims is $0.00-$772,744.37 and the estimated recovery is 100%.
- Class 4 (“General Unsecured Claims”) is impaired and entitled to vote on the Plan. The estimated aggregate amount of claims is $50.0mn to $307.0mn and the estimated recovery is .02-5%.
- Class 5 (“Intercompany Claims”) is impaired, deemed to reject and not entitled to vote on the Plan. The estimated aggregate amount of claims is N/A and the estimated recovery is 0%.
- Class 6 (“Interests”) is impaired, deemed to reject and not entitled to vote on the Plan. The estimated aggregate amount of claims is N/A and the estimated recovery is 0%.
Exhibits Filed:
- Exhibit B: The Wind Down Budget
- Exhibit C: The Liquidation Analysis.
A Plan confirmation status hearing is scheduled for January 29, 2019.
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