Contesting Confirmation (Series: Bankruptcy Battle Royale)

Copyright © 2019 by DailyDAC, LLC d/b/a Financial Poise Webinars™
Receive our free weekly newsletter at www.financialpoise.com/subscribe
Insert the cover image for this webinar on this slide entirely
1

Practical and entertaining education for
attorneys, accountants, business owners
and executives, and investors.
2

DISCLAIMER
The material in this webinar is for informational purposes only. It should not be
considered legal, financial or other professional advice. You should consult with an
attorney or other appropriate professional to determine what may be best for your
individual needs. While Financial Poise™ takes reasonable steps to ensure the information
it publishes is accurate, Financial Poise™ makes no guaranty in this regard.
About this PowerPoint: if you are looking at this PowerPoint without the benefit of
listening to the conversation that surrounded it then you are doing yourself a disservice.
This PowerPoint was prepared in contemplation of being viewed in conjunction with
listening to a one hour webinar on the topic
3

Thank You To Our Sponsor
4

5

6

MEET THE FACULTY
Moderator:
Mark Melickian – Sugar Felsenthal Grais & Helsinger LLP
Panelists:
Michael Riela – Tannenbaum Helpern
Michael Schwarzmann – Independent CRO and Restructuring Advisor
Thad Wilson – King & Spalding LLP
Rafael Zahralddin – Elliott Greenleaf
7

ABOUT THIS WEBINAR:
Contesting Confirmation
A chapter 11 plan of reorganization or liquidation is the document that controls the
methodology and order by which the debtor proposes to pay its creditors. The plan is
subject to comment and criticism by any party affected by it – namely, each and every
creditor of the debtor, potential targets of causes of action that the debtor may have, and
parties that may have potential causes of action against the debtor. Confirmation of a plan
is commonly a key goal in a chapter 11 case. Why? And trying to confirm one is often rife
with dispute and litigation. Why? This webinar explores this process and provides
guidance as to how to both defend and attack the confirmation of a debtor’s chapter 11
plan.
8

ABOUT THIS SERIES:
Bankruptcy Battle Royale – Common
Committee Controversies
No matter how you are involved in a Chapter 11 bankruptcy proceeding, there is a real
chance you will wind up litigating some issue. Litigating in bankruptcy court, however, is
very different than litigating in any other federal or state court because the customs, rules
and players are all different. This webinar is designed for the litigator who does not
generally find herself in front of a bankruptcy judge.
9

EPISODES IN THIS SERIES
2/26/19 Episode #1:
Cash Collateral and DIP Loan Contests
3/26/19 Episode #2:
Anatomy of a Preference
4/23/19 Episode #3:
Anatomy of a Fraudulent Transfer
5/21/19 Episode #4:
1
0
Dates shown are premiere dates.
All webinars will be available
On Demand approximately 4 weeks
after they premiere.

Episode #4:
1
1

INTRODUCTION TO CHAPTER 11 PLANS
• The primary purpose of a Chapter 11 plan is to implement a debtor’s restructuring, which
can be either a true reorganization or a controlled liquidation. A plan is a powerful device
that can, among other things:
✓ Divide creditors’ claims into different classes, and provide that some or even all classes
will be paid less than full or be otherwise impaired
✓ Retain, transfer or sell the debtor’s property
✓ Satisfy or modify liens
✓ Assume or reject contracts
✓ Cure or waive defaults
✓ Cancel and replace stock issuances
✓ Alter the debtor’s organizational documents and voting rights
1
2

EXCLUSIVITY
• The Debtor has an exclusivity period of 120 days to propose a plan, and an additional 180 days
after that to seek acceptance of the plan. (11 U.S.C. § 1121(b) and (c)(3)). Other parties in interest
may propose a plan after the exclusive period ends. The 120-day exclusivity period may be
extended or reduced “for cause”. “Cause” is not defined, but factors that courts have looked at
include, but are not limited to:
✓ Size and complexity of the case
✓ Necessity of sufficient time for the debtor to negotiate a plan and prepare a disclosure
statement
✓ Good faith progress toward reorganization
✓ Whether the debtor is paying its bills as they come due
✓ Whether the debtor has reasonable prospects for a viable plan
✓ Progress in negotiations with creditors
✓ Unresolved contingencies
1
3

TYPES OF PLANS
• While there are no “official categories” of chapter 11 plans, bankruptcy practitioners use a handful of
descriptive terms to describe the most common approaches to plans:
✓ Reorganization plan – A reorganization plan is one in which the debtor company or companies survive
and emerge from bankruptcy after paying creditors through a confirmed chapter 11 plan. The surviving
entity is generally smaller in size, scope of operations, and/or geographic range. At least some of
existing equity remains equity, or a body of creditors may trade debt for equity and emerge as the new
owners of the Old Co. True reorganization plans are increasingly rare.
✓ Liquidating plan – A liquidating plan is a plan that proposes to liquidate and distribute assets to
creditors in conjunction with the wind down/dissolution of the corporate entity. The assets of the entity
may survive, having been sold as a going concern to a third party or piecemeal to various third parties,
leaving behind cash, cash equivalents (e.g., A/R), and other assets (typically, litigation claims) to be
liquidated and distributed through the plan. A liquidating trustee is often appointed to oversee the
post-confirmation liquidation.
1
4

TYPES OF PLANS (cont’d)
✓ “Pot” plan – A “pot” plan is a plan that distributes a “pot” of assets typically left behind
after corporate assets are sold. Liquidating plans are generally a form of “pot” plan.
✓ Pre-packaged plan (“prepack”) – Generally associated with large companies – public
companies or large private companies backed by institutional investors. Solicitation of
votes on the plan is accomplished before the bankruptcy filing and is blessed by the
bankruptcy court after the bankruptcy filing. Pre-packs are generally reorganization
plans and commonly involve debt for equity trades in which existing institutional
creditors swap their claims for equity in the reorganized company.
1
5

PLAN PROPONENTS
• A chapter 11 plan may have one or more proponents. Typically, the debtor is one proponent and
may be the sole proponent. Increasingly, plans are proposed jointly by debtors and official
committees of unsecured creditors.
• Reorganization plan – The proponent is always the debtor, and the debtor is typically the only
proponent.
• Liquidating plan – The proponent may be the debtor alone, but more typically, the debtor and
creditor’s committee are co-proponents of a liquidating plan, because the creditor’s committee
represents the parties with the true economic stake in the outcome of the plan.
• With reorganization plans, and (in some cases) liquidating plans in which the debtor is the sole
proponent, the debtor and creditor’s committee may be at odds over the proposed plan’s
treatment of unsecured creditors, and the creditor’s committee may ultimately object to the
proposed plan and force the issue into litigation – i.e., a contested confirmation.
1
6

ADEQUATE DISCLOSURE
• The proponent of a plan must provide a disclosure statement to every person entitled to vote on a
plan. The disclosure statement must be approved by the bankruptcy court, and must provide
“adequate information” of a kind, and in sufficient detail, that would enable a hypothetical
investor to make an informed judgment about the plan. (11 U.S.C. § 1125).
• Types of information customarily incorporated into disclosure statements include, but are not
limited to:
✓ The circumstances that gave rise to the bankruptcy case
✓ Description of available assets
✓ Anticipated future of the debtor
✓ Sources of the information provided in the disclosure statement
1
7

ADEQUATE DISCLOSURE (cont’d)
✓ A liquidation analysis, comparing the plan to a hypothetical Ch. 7
✓ Accounting and valuation methods
✓ Future management of the debtor
✓ Discussion of risks associated with the plan
✓ Description of non-bankruptcy litigation
✓ Tax consequences of the plan
1
8

ADEQUATE DISCLOSURE (cont’d)
• What constitutes “adequate information” in a particular case depends on the complexity of the
case, the benefit of additional information to creditors and other parties in interest, and the cost
of providing additional information.
• Additional factors that courts may consider include, but are not limited to:
✓ The need for relative speed in plan solicitation and confirmation
✓ The need for investor protection
✓ The benefit of providing additional information, weighed against the cost
✓ Types of creditors and claims
✓ Creditors’ access to information from other sources
✓ What is reasonable practicable given the debtor’s economic state and history
✓ The condition of the debtor’s books and records.
1
9

STATEMENTS OF SUPPORT OR
DISAGREEMENT
• Plan proponents and opponents often request that additional materials in support of or
opposition to a plan be distributed to voting creditors along with the plan and disclosure
statement, or may distribute such additional materials themselves.
• The question of whether additional materials must be approved by the court often hinges on
whether they are considered “plan solicitation” materials, and thus come within the
requirements of 11 U.S.C. § 1125.
2
0

CONFIRMATION STANDARDS –
COMPLIANCE WITH TITLE 11
• To be confirmed, a plan must not only meet the express confirmation requirements of §
1129, but must also:
✓ Properly classify all claims and interests under § 1122
✓ Include all information required by § 1123
✓ Comply with all other sections of the Bankruptcy Code
• Additionally, the plan proponent’s actions must comply with the Bankruptcy Code,
including a proper disclosure statement and proper solicitation procedures under 11 U.S.C. §
1125.
2
1

SUBSTANTIVE CONSOLIDATION
• A plan may provide that a Debtor be substantively consolidated with one or more of its
affiliates—and thus share assets and liabilities for purposes of the plan—under certain
circumstances. Substantive consolidation can be unfair to creditors who dealt with a Debtor
affiliate who ran a surplus, as opposed to a Debtor affiliate who ran a deficit. Accordingly,
substantive consolidation is used sparingly
2
2

SUBSTANTIVE CONSOLIDATION (cont’d)
• Bankruptcy courts have adopted many different standards for substantive consolidation.
The various tests consider factors such as:
✓ Whether the benefits of substantive consolidation outweigh the harm to objecting
creditors
✓ The degree of difficulty in segregating and ascertaining individual assets and liabilities
✓ Majority ownership of one entity by another, and commonality of management
✓ Commingling of assets and business functions (entanglement)
✓ Intercompany guarantees and loans
✓ Transfers of assets without observance of corporate functions
2
3

APPROVAL BY CREDITORS
• Pursuant to § 1126, a class of creditors entitled to vote on a plan will be deemed to have
accepted the plan if creditors in the class holding at least 2/3 in dollar amount and 1/2 in
number vote to accept the plan.
• A creditor’s vote may be “designated” (ie, disallowed) under § 1126(e), if it acts in bad faith
in voting or soliciting votes for or against the plan. A vote may be in bad faith if, for example,
it was designed to (1) assume control of the debtor; (2) put the debtor out of business; (3)
destroy the debtor out of pure malice; or (4) obtain benefits under a private agreement with
a third party which depends on the debtor’s failure to reorganize.
2
4

APPROVAL BY CREDITORS (cont’d)
• Courts are divided as to whether subordination and intercreditor agreements in
loan documents, which provide for one creditor to control another creditor’s vote
on a bankruptcy plan, are enforceable.
2
5

VALUATION DISPUTES
• Two factors the court must consider when determining whether to confirm a Chapter 11 plan
are whether:
✓ The value that is to be received by impaired classes is at least equal to what they would
receive in a Chapter 7 liquidation
✓ Confirmation of the plan is likely to be followed by the liquidation or further
reorganization of the debtor
• If a dispute arises between the debtor and other parties in interest regarding the value of the
debtor’s assets and operations, an evidentiary hearing may be necessary to determine such
values.
2
6

VALUATION DISPUTES – EXPERT
WITNESSES
• Resolution of valuation issues often requires the testimony of expert witnesses.
• Valuation methodologies often employed by experts include:
✓ Discounted cash flow
✓ Comparable company
✓ Comparable transaction
2
7

FEASIBILITY
• A plan will be confirmed only if confirmation “is not likely to be followed by the
liquidation, or the need for further financial reorganization . . . unless such
liquidation or reorganization is proposed in the plan.” 11 U.S.C. § 1129(a)(11).
• To support this “feasibility” requirement, the debtor must show, by a
preponderance of the evidence, that the plan has a reasonable assurance of
commercial viability or a reasonable probability of success.
2
8

CRAMDOWN
• The bankruptcy court can confirm a plan even if a class of claims and interests
does not vote in favor of it. This is called “cramdown.” 11 U.S.C. § 1129(b)(1).
• In order to cram a plan down upon one or more dissenting classes, the court
must find that the plan “does not discriminate unfairly, and is fair and equitable,
with respect to each class of claims and interests that is impaired under, and has
not accepted, the plan.” Also, at least one impaired class must have voted to
accept the plan.
2
9

CRAMDOWN – UNFAIR
DISCRIMINATION
• “Unfair discrimination” is not defined in the Bankruptcy Code. But courts have
developed tests which look at not whether there was discrimination (there always is),
but whether the discrimination is unfair. Four factors are examined:
✓ Reasonable basis for discrimination
✓ Could plan come to fruition without the discrimination
✓ Was discrimination proposed in good faith
✓ Relationship between discrimination and rationale
3
0

CRAMDOWN – SECURED CLAIMS
• If a plan is crammed down on a class of secured creditors, the court will look at three
distribution alternatives (11 U.S.C. § 1129(b)(2)(A)):
✓ The secured creditor must receive deferred cash payments equal to the value of the
creditor’s collateral in the bankruptcy estate. The appropriate interest rate is often
litigated.
✓ The collateral is sold under the plan, subject to the secured creditor’s right to credit
bid.
✓ The secured creditor receives the “indubitable equivalent” of the value of the
collateral.
3
1

CRAMDOWN – ABSOLUTE PRIORITY
RULE
• For a plan to be crammed down on a class of unsecured creditors, the plan must
provide that a class must be paid in full before any junior classes receive any
distribution.
• In some cases, courts have approved sharing agreements, where a class of senior
creditors agrees to give a portion of its distribution under a plan to a class of
junior creditors, over the objection of a dissenting class.
3
2

CRAMDOWN – GERRYMANDERING
• Because a plan must be approved by at least one impaired class, a plan
proponent has an incentive to create an impaired class that will vote in favor of
the plan.
• The plan proponent may “gerrymander” a class by structuring it to ensure a
favorable vote (see § 1122(a)), or by artificially impairing a class with an
insignificant or de minimin impairment to manipulate the confirmation process
(see § 1124).
3
3

RELEASE OF NONDEBTORS
• Chapter 11 plans often include provisions releasing nondebtor entities—frequently insiders and
affiliates—from liabilities relating to the debtor or the bankruptcy case. Factors that courts look
at in determining whether to allow such releases include, but are not limited to:
✓ Identity of interest between debtor and third party—would suit against nondebtor deplete
assets of bankruptcy estate?
✓ Substantial contribution by nondebtor to assets of reorganization
✓ Will lack of release affect debtor’s ability to reorganize?
✓ Agreement by a substantial majority of creditors to the release
✓ Whether plan pays substantially all claims of creditors affected by the release
✓ Scope of release
✓ Whether the release affects matters beyond the jurisdiction of the bankruptcy court
3
4

EFFECT OF CONFIRMATION – FREE
AND CLEAR OF LIENS
• Upon plan confirmation, property dealt with by the plan is free and clear of claims and
interests of creditors, equity security holders and general partners of the debtor. (§
1141(c)). This issue most commonly arises when a lienholder seeks to enforce its security
interest against a reorganized debtor after plan confirmation. Most courts hold that, if
the creditor participates in the reorganization, the lien is extinguished upon
confirmation, unless the plan provides otherwise.
3
5

EFFECT OF CONFIRMATION – CLAIM
DESCRIPTION; RES JUDICATA
• The bankruptcy court’s confirmation of a Chapter 11 plan constitutes a final
judgment on the merits of all claims, and is given the preclusive effect of res
judicata. There is an exception where the plan reserves a litigant’s right to
pursue a claim after bankruptcy. Most courts hold that the reservation of rights
must be specific as to the particular claim, and may not be a blanket reservation.
3
6

EFFECT OF CONFIRMATION –
SUCCESSOR LIABILITY
• Chapter 11 plans often vest substantial assets of the bankruptcy estate—sometimes
substantially all of the assets—in assignees or successor entities. Most bankruptcy courts
are reluctant to upset the general, non-bankruptcy rule that the transferee of assets is
not liable for claims that arose from the conduct of the transferor-debtor, absent the
existence of well established exceptions, such as express or implied agreement by the
transferee to assume a liability.
3
7

EFFECT OF CONRIRMATION –
SUBSTANTIAL CONSUMMATION
• Bankruptcy courts are frequently confronted with appeals by creditors after a
sale has taken place or a plan confirmed. Many courts decline to hear such
appeals on the grounds of “equitable mootness” where the plan is so
substantially consummated that effective relief is, as a practical matter,
unavailable. “Substantial consummation” is defined at § 1101(2).
3
8

REVOCATION OF CONFIRMATION
• A party in interest may seek revocation of an order confirming a Chapter 11 plan (§
1144). The motion must be made within 180 days after the confirmation order is
entered, and proper notice must be given. The confirmation order will be revoked only if
the court finds it was procured by fraud.
• An order revoking a confirmation order must:
✓ Contain provisions necessary to protect entities acquiring rights in good faith
reliance on the confirmation order; and
✓ Revoke the discharge of the debtor.
3
9

ABOUT THE FACULTY
4
0

Mark Melickian – mmelickian@sfgh.com
Mark Melickian leads Sugar Felsenthal Grais & Helsinger LLP’s restructuring practice. Over the past 20 plus
years, he has worked primarily on business transactional and litigation matters with a focus on chapter 11
commercial bankruptcy cases and non-bankruptcy distressed situations. His practice includes both debtor-
and creditor-side representations and include financial institutions, indenture trustees, trade creditors, asset
purchasers, investors, commercial real estate interests, corporate officers, and other parties in interest in
chapter 11 cases throughout the country. In addition, a significant focus of his practice is the representation of
committees and other estate fiduciaries in bankruptcy cases – over the past two decades, he has counseled
dozens of official and unofficial bankruptcy committees, liquidating trustees, litigation trustees, and plan
administrators charged with pursuing and liquidating assets for the benefit of estate creditors.
Mark has written extensively on bankruptcy and insolvency law and other topics, having contributed materials
on these subjects to American Bankruptcy Institute Journal, Bankruptcy Strategist, Wiley Bankruptcy Law
Update, Ginsberg & Martin on Bankruptcy, Norton Bankruptcy Law Adviser, the Cornell University Legal
Ethics Library, and dozens of professional conferences and seminars. For several years, he wrote a monthly
legal affairs column for Student Lawyer, an America Bar Association publication, for which he received the
Peter Lisagor Award for Exemplary Journalism from the Chicago chapter of the Society of Professional
Journalists. He is a graduate of Colorado State University and Northwestern University School of Law.
4
1

Michael Riela – Riela@thsh.com
Mike Riela is a partner in Tannenbaum Helpern’s Creditors’ Rights and Business Reorganization practice. With
more than 15 years of experience, Mike advises companies on complex restructuring, distressed M&A, loan
transactions and bankruptcy related litigation matters. Mike has in-depth experience in advising clients on
corporate and real estate bankruptcies, workouts, Chapter 11 and Chapter 7 bankruptcy cases, debtor-in-
possession (DIP) and bankruptcy exit loan facilities, secondary market trading of distressed debt and trade
claims, Section 363 sales and bankruptcy retention and fee agreements and disputes. His clients include banks,
administrative agents, indenture trustees, hedge funds, private equity firms, professional services firms, trade
creditors, contract counterparties, shareholders, debtors and investors.
Mike has represented buyers of assets in Section 363 and out-of-court sales from sellers such as Evergreen
Solar, Inc., Sonic Telecommunications International, Ltd, Urban Communicators PCS Limited Partnership, US
Aggregate, Inc., and Vectrix Corporation, as well as representing lenders, trustees and administrative agents in
major Chapter 11 cases and workouts such as Delta Air Lines, Inc., Extended Stay Inc., Buffets Inc., Legends
Gaming LLC, Nortel Networks, Premier International Holdings Inc., and many others.
To read more, go to https://www.financialpoise.com/financialpoisewebinars/faculty/michael-riela/
4
2

Michael Schwarzmann – michaelschwarzmann@yahoo.com
Michael Schwarzmann has over 20 years’ experience helping identify opportunities to create value for his
clients. I have extensive experience working with established companies when they encounter financial
difficulties by assisting them in developing solutions to address short term cash needs and longer term
profitability. My process includes helping to identify cost savings and value capture scenarios by analyzing
historical financial performance along with current operations and projecting optimizing strategies. Utilizing
weekly and monthly cash flow statements, budgets, and forecasts, I utilize a focused, data driven approach to
identifying opportunities to increase company profitability. Through a broad review of financial, operational
and strategic performance, I help guide companies to increased profitability. Working across the organization,
vertically and horizontally, uncovers additional solutions and generates greater buy-in of the goals, objectives
and action plan, all of which are critical to maximize the impact of proposed changes. I utilize my legal
knowledge to seamlessly work with counsel to identify and address legal issues in a more cost effective manner.
I have guided the development and evaluation of business plans and formulated successful strategies to
preserve or improve asset values. I am a consensus builder. Industry experience includes: health care,
manufacturing, agricultural, construction, restaurants and franchising, energy and travel.
4
3

Thad Wilson – ThadWilson@KSLAW.com
Thad Wilson is a partner in the Atlanta office of King & Spalding and a member of the firm’s Financial
Restructuring practice. Thad has represented a broad spectrum of clients in financial restructuring, corporate and
insolvency matters, including bankruptcy-related government investigations and appeals. He has represented
debtors, secured and unsecured creditors, and other parties in interest in major Chapter 11 bankruptcy cases. Thad
has substantial experience representing litigants in contested matters, adversary proceedings and other high stakes
litigation in significant Chapter 11 bankruptcy cases and insolvency proceedings involving creditors’ rights,
fraudulent transfers, and alter ego, as well as representing buyers and sellers of distressed assets in Chapter 11
bankruptcy proceedings. Thad is a member of the American Bankruptcy Institute, the Turnaround Management
Association, the Atlanta Bar Association and the State Bar of Georgia. He is a founding member of the Atlanta
chapter of the Turnaround Management Association NextGen organization and is the current president-elect of its
board. In 2014, he was elected to the initial class of Barristers of the W. Homer Drake, Jr. Georgia Bankruptcy
American Inn of Court, of which he is currently a member. Thad is a frequent lecturer on bankruptcy-related issues
before bar groups and in continuing legal education programs. Thad has authored and co-authored numerous
articles on bankruptcy-related topics and has been published in numerous publications. Thad received his law
degree from the University of Iowa College of Law, with distinction.
4
4

Rafael Zahralddin – RXZA@elliottgreenleaf.com
Rafael X. Zahralddin-Aravena is a Shareholder, Director, and Chair of his firm’s Commercial
Bankruptcy and Restructuring Practice. He founded the Elliott Greenleaf Delaware office in 2007,
which specializes in business law, as its first Managing Shareholder. He works as a litigator and
advises businesses on issues of compliance, corporate formation, corporate governance, insolvency,
distressed mergers and acquisition, commercial transactions, cyber law, and international and cross
border issues.
He has been lead counsel in several significant matters including serving as special litigation
counsel in Washington Mutual, the largest bank insolvency in U.S. history. In the Nortel
bankruptcies, he successfully secured a settlement of more than $50 million for the permanently
disabled former employees of the company. The firm and Mr. Zahralddin were named among the
firms that received multiple awards in 2014, culminating in the Large Company Transaction of the
Year Award from the Turnaround Management Association for their work in the AgFeed USA, Inc.
bankruptcy, which involved the sale of the U.S. and China assets of a publicly traded company.
4
5

QUESTIONS OR COMMENTS?
If you have any questions about this webinar that you did not get to ask during
the live premiere, or if you are watching this webinar On Demand, please do
not hesitate to email us at info@financialpoise.com with any questions or
comments you may have. Please include the name of the webinar in your email
and we will do our best to provide a timely response.
IMPORTANT NOTE: The material in this presentation is for general educational purposes only. It has been prepared primarily
for attorneys and accountants for use in the pursuit of their continuing legal education and continuing professional education.
4
6

ABOUT DailyDAC
DailyDAC.com is the leading source of
information about assignments, article 9,
bankruptcy, receiverships, out-of-court workouts
and vulture investing, designed for business
owners and vulture investors.
Visit us at www.dailydac.com.
4
7
Premium Public Notice Service
DailyDAC’s Premium Public Notice Service helps market asset
sales on behalf of fiduciaries (e.g., Chapter 11 debtors-in-
possession and committees, trustees, receivers, assignees),
secured lenders selling collateral under UCC Article 9, and
auctioneers to a very large and self-selected group of potential
bidders and their advisors. The Service also assists with noticing
other events, deadlines, and milestones – including tombstones
and other press releases.
Our free weekly newsletter, DailyDAC contains our latest
bankruptcy article, current Public Notices and all
opportunistic deals added to our proprietary database
that week. Sign up at:
https://www.dailydac.com/dacyak-weekly-newsletter-signup/

ABOUT FINANCIAL POISE
DailyDAC LLC, d/b/a Financial Poise™ provides
continuing education to attorneys, accountants,
business owners and executives, and investors. Its
websites, webinars, and books provide Plain
English, entertaining, explanations about legal,
financial, and other subjects of interest to these
audiences.
Visit us at www.financialpoise.com.
4
8
Our free weekly newsletter, Financial Poise
Weekly, educates readers about business,
business law, finance, and investing. To receive
it simply add yourself by going to:
https://www.financialpoise.com/newsletter/
Email addresses are never sold to or shared
with third parties.

Contesting Confirmation (Series: Bankruptcy Battle Royale)

Empfohlen

Empfohlen

Weitere ähnliche Inhalte

Mehr von Financial Poise

Mehr von Financial Poise (20)

Kürzlich hochgeladen

Kürzlich hochgeladen (20)

Contesting Confirmation (Series: Bankruptcy Battle Royale)