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Full title: Stipulation to Allow Claims Stipulation Allowing Filing of Late Filed Proof of Claim of Creditor City of Novato Filed by Debtor Professional Financial Investors, Inc.. (Klinger, Matthew) (Entered: 08/05/2021)

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

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The above-captioned debtor (“Professional Investors”) and its affiliated debtors 22 (collectively, “Debtors”) and the City of Novato (“City”) hereby enter into this Stipulation (the 23 “Stipulation”), and file this Stipulation regarding the City’s late filed proof of claim asserting a 24 general unsecured claim in the amount of $14,800.00, Claim No. 150 as filed in the Bankruptcy 25 Court’s Claims Register on July 29, 2021 (the “City’s POC”).575] 8 establishing certain dates by which non-investor parties holding prepetition claims against any of 9 the Debtors must file proofs of claim (the “Bar Date Order”).The Bar Date Order set various 10 deadlines for governmental units, as defined in section 101(27) of the Bankruptcy Code, to file 11 claims against the Debtors, including (i) a deadline of May 13, 2021 for governmental units to file12 claims against Professional Investors and Professional Investors Security Fund, Inc. and (ii) a 13 deadline of June 9, 2021 for governmental units to file claims against those certain LLC/LP 14 Debtors (as defined in the Bar Date Order) for which Orders for Relief were entered on December15 11, 2020, 16The City’s POC [Claim No. 150 as filed in the Bankruptcy Court’sNotwithstanding the terms and conditions of this Stipulation and any actions taken 16 pursuant to such terms or conditions, nothing in this Stipulation shall be deemed: (a) an admissio17 as to the amount of, basis for, or validity of any claim against a Debtor entity under the 18 Bankruptcy Code or other applicable non-bankruptcy law; (b) a waiver of any Debtors’ or any 19 other party in interest’s right to dispute any claim on any grounds; (c) a promise or requirement to20 pay any claim; (d) an implication or admission that any particular claim is of a type specified or 21 defined in the Stipulation or any order granting the relief requested by the Stipulation or a finding22 that any particular claim is an administrative expense claim or other priority claim; (e) a request o23 authorization to assume, adopt, or reject any agreement, contract, or lease pursuant to section 365 24 of the Bankruptcy Code; (f) an admission as to the validity, priority, enforceability, or perfection o25 any lien on, security interest in, or other encumbrance on property of the Debtors’ estates; (g) a 26 waiver or limitation of any of the Debtors’, or any other party in interest’s, rights under the 27 Bankruptcy Code or any other applicable law; or (h) a concession by any of the Debtors that any 28 liens (contractual, common law, statutory, or otherwise) that may be satisfied pursuant to this 1 Stipulation are valid, and the rights of all parties in interest are expressly reserved to contest the 2 extent, validity, or perfection or seek avoidance of all such liens.

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Document Contents

1 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP A Limited Liability Partnership 2 Including Professional Corporations ORI KATZ, Cal. Bar No. 209561 3 J. BARRETT MARUM, Cal. Bar No. 228628 MATT R. KLINGER, Cal. Bar No. 307362 4 GIANNA SEGRETTI, Cal. Bar No. 323645 Four Embarcadero Center, 17th Floor 5 San Francisco, California 94111-4109 Telephone: 415.434.9100 6 Facsimile: 415.434.3947 E mail okatz@sheppardmullin.com 7 bmarum@sheppardmullin.com mklinger@sheppardmullin.com 8 gsegretti@sheppardmullin.com 9 Counsel for Debtors 10 UNITED STATES BANKRUPTCY COURT 11 NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION 12 13 In re Case No. 20-30604 14 PROFESSIONAL FINANCIAL (Jointly Administered) 15 INVESTORS, INC., a California corporation, et al Chapter 11 16 Debtors. STIPULATION ALLOWING FILING OF 17 LATE-FILED PROOF OF CLAIM OF CREDITOR CITY OF NOVATO 18 19 Judge: Hon, Hannah L. Blumenstiel 20 21 The above-captioned debtor (“Professional Investors”) and its affiliated debtors 22 (collectively, “Debtors”) and the City of Novato (“City”) hereby enter into this Stipulation (the 23 “Stipulation”), and file this Stipulation regarding the City’s late filed proof of claim asserting a 24 general unsecured claim in the amount of $14,800.00, Claim No. 150 as filed in the Bankruptcy 25 Court’s Claims Register on July 29, 2021 (the “City’s POC”). 26 WHEREAS, on July 26, 2020, Professional Investors filed a voluntary petition (the “Main27 Bankruptcy Case”) for relief under chapter 11 of Title 11 of the United States Code (the 28

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1 “Bankruptcy Code”) in the United States Bankruptcy Court for the Northern District of California2 (the “Bankruptcy Court”). 3 WHEREAS, on August 18, 2020, Professional Investors filed its Global Notes to 4 Schedules of Assets and Liabilities [Docket No. 57] (the “Schedules”) in which it scheduled two 5 contingent unsecured claims for the City in the amount of $230 and $252. [Docket No. 57, at 6 pp. 78–79 of Schedule E/F]. 7 WHEREAS, on April 19, 2021, the Bankruptcy Court entered an order [Docket No. 575] 8 establishing certain dates by which non-investor parties holding prepetition claims against any of 9 the Debtors must file proofs of claim (the “Bar Date Order”). The Bar Date Order set various 10 deadlines for governmental units, as defined in section 101(27) of the Bankruptcy Code, to file 11 claims against the Debtors, including (i) a deadline of May 13, 2021 for governmental units to file12 claims against Professional Investors and Professional Investors Security Fund, Inc. and (ii) a 13 deadline of June 9, 2021 for governmental units to file claims against those certain LLC/LP 14 Debtors (as defined in the Bar Date Order) for which Orders for Relief were entered on December15 11, 2020, 16 WHEREAS, the Debtors properly served the City with notice of the claims bar dates for 17 governmental units as set forth in the Bar Date Order. [Dkt. No. 608, at p. 274]. 18 WHEREAS, the City asserts it has no record of receiving notice of the claims bar dates fo19 governmental units. 20 WHEREAS, despite the foregoing, the Parties have agreed to deem the City’s POC as 21 timely filed, subject to the conditions set forth in this Stipulation. 22 THEREFORE, IT IS STIPULATED AND AGREED as follows: 23 1. The City’s POC [Claim No. 150 as filed in the Bankruptcy Court’s Claims Register 24 on July 29, 2021] shall be deemed timely filed. 25 2. The Parties shall retain any and all rights and defenses with respect to the City’s PO26 including with respect to the validity, amount, and liability. Nothing herein shall constitute or be 27 deemed to constitute an admission of liability by any of the Debtors with respect to the City’s 28 POC.

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1 3. This Stipulation shall not become effective unless and until it is approved and entere2 by the Bankruptcy Court. 3 4. Neither the Stipulation nor any negotiations and writings in connection with this 4 Stipulation shall in any way be construed as or deemed to be evidence of or an admission on 5 behalf of any party regarding any claim or right that such party may have against the other party, 6 other than as provided herein. 7 5. The provisions of this Stipulation shall only apply to the general unsecured claims 8 against any of the Debtors set forth in the City’s POC and shall not apply to any other claims the 9 City has or may have against any of the Debtors. 10 6. Each of the Parties represents and warrants it is duly authorized to enter into and be 11 bound by this Stipulation. 12 7. This Stipulation may be executed in multiple counterparts, any of which may be 13 transmitted by facsimile or electronic mail, and each of which shall be deemed an original, but all14 of which together shall constitute one instrument. 15 8. Notwithstanding the terms and conditions of this Stipulation and any actions taken 16 pursuant to such terms or conditions, nothing in this Stipulation shall be deemed: (a) an admissio17 as to the amount of, basis for, or validity of any claim against a Debtor entity under the 18 Bankruptcy Code or other applicable non-bankruptcy law; (b) a waiver of any Debtors’ or any 19 other party in interest’s right to dispute any claim on any grounds; (c) a promise or requirement to20 pay any claim; (d) an implication or admission that any particular claim is of a type specified or 21 defined in the Stipulation or any order granting the relief requested by the Stipulation or a finding22 that any particular claim is an administrative expense claim or other priority claim; (e) a request o23 authorization to assume, adopt, or reject any agreement, contract, or lease pursuant to section 365 24 of the Bankruptcy Code; (f) an admission as to the validity, priority, enforceability, or perfection o25 any lien on, security interest in, or other encumbrance on property of the Debtors’ estates; (g) a 26 waiver or limitation of any of the Debtors’, or any other party in interest’s, rights under the 27 Bankruptcy Code or any other applicable law; or (h) a concession by any of the Debtors that any 28 liens (contractual, common law, statutory, or otherwise) that may be satisfied pursuant to this

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1 Stipulation are valid, and the rights of all parties in interest are expressly reserved to contest the 2 extent, validity, or perfection or seek avoidance of all such liens. 3 9. Similarly, notwithstanding the terms and conditions of this Stipulation and any 4 actions taken pursuant to such terms or conditions, nothing in this Stipulation shall be deemed a 5 waiver of the City’s rights to object or otherwise address events that occurred in the case prior to i6 receiving proper notice. 7 10. The Bankruptcy Court shall retain jurisdiction to hear any disputes relating to or 8 arising from this Stipulation. 9 10 Dated: August 5, 2021 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP 11 12 By /s/ Matt Klinger ORI KATZ 13 J. BARRETT MARUM MATT KLINGER 14 GIANNA SEGRETTI 15 Counsel for Debtors 16 17 Dated: August 5, 2021 COLANTUONO, HIGHSMITH & WHATLEY, PC 18 19 By /s/ John L. Jones II JOHN L. JONES 20 21 Counsel for City of Novato 22 23 24 25 26 27 28

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