HTML Document View

Full title: Joinder to Objection (Limited) to Joint Motion for Conditional Approval of Disclosure Statement for Joint Chapter 11 Plan of Professional Investors, Inc. and its Affiliated Debtors Proposed by the Debtors and the Official Committee of Unsecured Creditors (RE: related document(s)559 Objection). Filed by Creditor OneUnited Bank (McDermott, Christopher) (Entered: 04/14/2021)

Document posted on Apr 13, 2021 in the bankruptcy, 4 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Joinder to Objection (Limited) to Joint Motion for Conditional Approval of Disclosure Stateme 4 for Joint Chapter 11 Plan of Professional Investors, Inc. and its Affiliated Debtors Proposed by th 5 Debtors and the Official Committee of Unsecured Creditors (“Limited Objection”) filed by T 6 Counties Bank (“TCB”) at docket no. 7 OneUnited’s Claim has an approximate balance of $4,946,219.39 and title to the Propert 8 is currently in the name of Professional Investors Security Fund XII (“PISF XII”).(“Non-Investor Lenders”) in th 10 Disclosure Statement1 and Plan.However, like TCB, OneUnited remains concerned over the lack of disclosure as it pertain 15 to the potential litigation targets and claims against the Non-Investor Lenders.On April 14, 2021, I caused the following documents: 24  ONEUNITED BANK'S NOTICE OF JOINDER TO OBJECTION (LIMITED) TOJOINT MOTION FOR CONDITIONAL APPROVAL OF DISCLOSURE 25 STATEMENT FOR JOINT CHAPTER 11 PLAN OF PROFESSIONAL FINANCIAL INVESTORS,

Document Contents

cmcdermott@aldridgepite.com 2 Eddie R. Jimenez (SBN 231239) ejimenez@aldridgepite.com 3 ALDRIDGE PITE, LLP 4375 Jutland Drive, Suite 200 4 P.O. Box 17933 San Diego, CA 92177-0933 5 Telephone: (858) 750-7600 Facsimile: (619) 590-1385 6 Attorneys for OneUnited Bank 7 8 UNITED STATES BANKRUPTCY COURT 9 NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION 10 In re Case No. 20-30604 (Jointly Administered with Case Nos. 20- 11 PROFESSIONAL FINANCIAL 30908, 20-30909, 20-30910, 20-30911, 20-INVESTORS, INC., et al., 30912, 20-30913, 20-30914, 20-30915, 20- 12 30916, 20-30917, 20-30919, 20-30920, 20- Debtors. 30922, 20-30923, 20-30924, 20-30925, 20- 13 30927, 20-30928, 20-30929, 20-30930, 20- 30934, 20-30935, 20-30936, 20-30937, 20- 14 30938, 20-30939, 20-30940, 20-30941, 20- 30942, 21-30082, 21-30083, 21-30084, 21- 15 30085, 21-30086, 21-30087, 21-30088, 21- 30089, 21-30093, and 21-30094) 16 Chapter 11 17 ONEUNITED BANK'S NOTICE OF 18 JOINDER TO OBJECTION (LIMITED) TO JOINT MOTION FOR 19 CONDITIONAL APPROVAL OF DISCLOSURE STATEMENT FOR 20 JOINT CHAPTER 11 PLAN OF PROFESSIONAL FINANCIAL 21 INVESTORS, INC. AND ITS AFFILIATED DEBTORS PROPOSED 22 BY THE DEBTORS AND THE OFFICIAL COMMITTEE OF 23 UNSECURED CREDITORS 24 Hearing Date: April 15, 2021 25 Time: 11:00 a.m. Place: Telephonic/Video Appearance Only 26 Judge: Hon. Hannah L. Blumenstiel 27 28 -1- CASE NO. 20-3060

1

2 445 Ignacio Blvd., Novato, CA 94949 (“Property” or “Claim”), hereby submits this Notice 3 Joinder to Objection (Limited) to Joint Motion for Conditional Approval of Disclosure Stateme 4 for Joint Chapter 11 Plan of Professional Investors, Inc. and its Affiliated Debtors Proposed by th 5 Debtors and the Official Committee of Unsecured Creditors (“Limited Objection”) filed by T 6 Counties Bank (“TCB”) at docket no. 559. 7 OneUnited’s Claim has an approximate balance of $4,946,219.39 and title to the Propert 8 is currently in the name of Professional Investors Security Fund XII (“PISF XII”). The Claim i 9 classified as a Class 1 Non-Investor First-Priority Lender (“Non-Investor Lenders”) in th 10 Disclosure Statement1 and Plan. Counsel for OneUnited has only been recently engaged in thi 11 case but echoes the statements made by TCB that Debtors’ counsel and the Non-Investor Lenders 12 counsel have worked diligently over the past several weeks seeking to address the Non-Invest 13 Lenders’ concerns as it relates to the Disclosure Statement and Plan. 14 However, like TCB, OneUnited remains concerned over the lack of disclosure as it pertain 15 to the potential litigation targets and claims against the Non-Investor Lenders. Without such 16 disclosure, it renders OneUnited’s ability to make an informed decision to accept the Plan virtuall 17 impossible. As a result, OneUnited respectfully joins in the Limited Objection and requests furth 18 disclosures be made as it relates to these issues. 19 Respectfully submitted, 20 ALDRIDGE PITE, LLP 21 22 Dated: April 14, 2021 /s/ Christopher M. McDermott Attorneys for OneUnited Bank 23 24 25 26 27 28 1 Terms not defined herein shall have the same mean ascribed to them in the Limited Objection. -2- CASE NO. 20-3060

2

cmcdermott@aldridgepite.com 2 Eddie R. Jimenez (SBN 231239) ejimenez@aldridgepite.com 3 ALDRIDGE PITE, LLP 4375 Jutland Drive, Suite 200 4 P.O. Box 17933 San Diego, CA 92177-0933 5 Telephone: (858) 750-7600 Facsimile: (619) 590-1385 6 Attorneys for OneUnited Bank 7 8 UNITED STATES BANKRUPTCY COURT 9 NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION 10 In re Case No. 20-30604 (Jointly Administered with Case Nos. 20- 11 PROFESSIONAL FINANCIAL, 30908, 20-30909, 20-30910, 20-30911, 20- 30912, 20-30913, 20-30914, 20-30915, 20- 12 Debtor. 30916, 20-30917, 20-30919, 20-30920, 20- 30922, 20-30923, 20-30924, 20-30925, 20- 13 30927, 20-30928, 20-30929, 20-30930, 20- 30934, 20-30935, 20-30936, 20-30937, 20- 14 30938, 20-30939, 20-30940, 20-30941, 20- 30942, 21-30082, 21-30083, 21-30084, 21- 15 30085, 21-30086, 21-30087, 21-30088, 21- 30089, 21-30093, and 21-30094) 16 17 Chapter 11 18 PROOF OF SERVICE 19 I, Priscilla Johnson, declare that: 20 I am employed by Aldridge Pite, LLP. My business address is: 4375 Jutland Drive, Suite 20 21 P.O. Box 17933, San Diego, CA 92177-0933. I am over the age of eighteen years and not a party t 22 this cause. 23 On April 14, 2021, I caused the following documents: 24  ONEUNITED BANK'S NOTICE OF JOINDER TO OBJECTION (LIMITED) TOJOINT MOTION FOR CONDITIONAL APPROVAL OF DISCLOSURE 25 STATEMENT FOR JOINT CHAPTER 11 PLAN OF PROFESSIONAL FINANCIAL INVESTORS, INC. AND ITS AFFILIATED DEBTORS PROPOSE 26 BY THE DEBTORS AND THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS 27 28

3

2 thereon fully prepaid in the United States Mail, and/or via electronic means pursuant to Bankruptc 3 Local Rule 9013-3(c) as follows: 4 DEBTOR Professional Financial 5 350 Ignacio Blvd. 6 Suite 300 Novato, CA 94949 7 (Via U.S. Mail) 8 DEBTORS’ ATTORNEY 9 Ori Katz Sheppard, Mullin, Richter and Hampton 10 4 Embarcadero Center 17th Fl. San Francisco, CA 94111 11 (Via U.S Mail/NEF) 12 13 U.S. TRUSTEE U.S. Trustee 14 Department of Justice 15 USTPRegion17.sf.ecf@usdoj.gov (Via NEF) 16 17 I declare under penalty of perjury that the foregoing is true and correct. 18 Dated: April 14, 2021 /s/_Priscilla Johnson________________________ 19 20 21 22 23 24 25 26 27 28

4