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IN THE UNITED STATES BANKRUPTCY COURT


FOR THE DISTRICT OF CONNECTICUT
NEW HAVEN DIVISION

IN RE: : CHAPTER 11
:
CURTIS JAMES JACKSON, III, : CASE NO. 15-21233 (AMN)
:
DEBTOR. :

MOTION TO SCHEDULE STATUS CONFERENCE

Curtis James Jackson, III (the “Debtor”), the debtor and debtor in possession in the above-

captioned bankruptcy case (the “Bankruptcy Case”), filed under chapter 11 of title 11 of the United

States Code (the “Bankruptcy Code”), files this motion to request a status conference in this case

in order to report to the Court on remaining issues in the Bankruptcy Case. In support of his

Motion, the Debtor states as follows:

The Bankruptcy Case

1. On July 13, 2015 (the “Petition Date”), the Debtor filed a voluntary petition for relief

under chapter 11 of the Bankruptcy Code, thereby initiating the Bankruptcy Case.

2. On July 7, 2016, the Bankruptcy Court entered an order (the “Confirmation Order”)

[Dkt. No. 552] confirming Debtor’s Third Amended Plan of Reorganization (the “Plan”) [Dkt. No.

485]. Section 9.04 of the Plan provides for the discharge of all claims against the Debtor, except

for, inter alia, claims excepted from discharge under Section 523.

3. Also, on July 7, 2016, the Court entered an order granting the Debtor’s Motion for

Approval of Notice Procedure Related to Plan Deadlines [Dkt. No. 551] (the “Plan Notice Order”).

The Plan Notice Order provides that “[u]pon publication of the Plan Deadline Notice as set forth

herein, all known and unknown claimants shall have received actual or constructive notice of the

Debtor’s bankruptcy and the deadlines for filing proofs of claim or seeking the allowance and

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payment of administrative claims.” Plan Notice Order at ¶ 3 (emphasis added). Pursuant to that

Order, the final date to assert administrative expenses against the Debtor was thirty (30) days after

the “Effective Date” of the Plan.

4. On July 22, 2016 (the “Effective Date”) [Dkt. No. 583], the Plan went effective.

5. Following the Effective Date, the Debtor delivered $7.4 million to the Disbursing Agent

for payment of allowed administrative claims, allowed non-tax priority claims, allowed priority

tax claims, and allowed administrative convenience claims as well as to make interim distributions

of allowed general unsecured claims.

6. On December 2, 2016, the Debtor filed the following pleadings: (i) Motion for

Order Approving Settlement of Malpractice Claim [Dkt. No. 715] (the “Settlement Motion”); and

(ii) Motion for Approval and Entry of Stipulation and Agreed Order with Respect to Reduced

Distribution to Holders of Allowed Claims of Sleek Audio, LLC, Lastonia Leviston, and Suntrust

Bank, Inc. [Dkt. No. 714] (the “Agreed Distribution Motion” and, together with the Settlement

Motion, the “Motions”).

7. Pursuant to the Settlement Motion, the Debtor sought approval of a settlement of

the Malpractice Claim for, inter alia, a payment of $14.5 million.

8. Pursuant to the Agreed Distribution Motion, the Debtor sought approval and entry

of that certain Stipulation and Agreed Order (the “Agreed Order”), by and among the Debtor, Sleek

Audio, LLC (“Sleek”), ASM Capital V, L.P. (“ASM”), as assignee of the claim of SunTrust Bank,

Inc., and Lastonia Leviston (“Leviston” and, together with Sleek and ASM, the “Creditor Group”).

9. On December 15, 2016, the Court granted the Motions. [Dkt. Nos. 734, 735.]

10. As a result of the approval of the Settlement Motion and the agreements between

the Debtor and the Creditor Group set forth in the Agreed Order: (i) the Disbursing Agent was to

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receive all of the net proceeds of the Malpractice Claim (i.e., $13,649,999.16) directly from the

Malpractice Claim defendants; and (ii) the Debtor was required to contribute an additional

$1,308,508.00 to the Disbursing Agent to enable the Disbursing Agent to complete payment of all

Allowed General Unsecured Claims (subject to the provisions of the Plan with respect to Disputed

Claims).

11. On or about December 13, 2016, the Debtor wired $1,308,508.00 to the Disbursing

Agent, and the Disbursing Agent also received the Malpractice Claim settlement proceeds. Thus,

the Debtor completed all payments to the Disbursing Agent required under the Plan. The

Disbursing Agent then made a final distribution to Holders of Allowed General Unsecured Claims

(subject to the provisions of the Plan with respect to Disputed Claims). A chart setting forth the

amounts of General Unsecured Claims, Convenience Class Claims, and approved professional fees

as well as the total distributions on account of such claims is attached hereto as Exhibit A.

12. On February 2, 2017, the Court entered an order granting the Debtor a discharge of debts

(the “Discharge Order”) [Dkt. No. 764]. A copy of the Discharge Order is attached hereto as

Exhibit B.

Relief Requested

13. The Debtor respectfully requests that the Court schedule a status conference in this case.

The Debtor requests such conference so that he can report to the Court as to the status of pending

matters relating to this Bankruptcy Case. The Debtor proposes the following agenda for the status

conference:

a. Candace Scott and Dorothy DeJesus: On September 30, 2015, Dorothy

DeJesus (“DeJesus”) filed a Proof of Claim (Claim 3-1) (the “DeJesus Claim”), asserting

the amount of the claim as $65,825.00 and stating as the basis for the claim “Judgment (the

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“Judgment”) for Assault, Battery, False Imprisonment[.]” On the same day, Candace Scott

(“Scott”) filed a nearly identical Proof of Claim (Claim 4-1) (the “Scott Claim” and

together with the DeJesus Claim, the “Claims”), asserting the amount of the claim as

$65,725.00 and stating as the basis for the claim the Judgment. The Claims were

subsequently declared nondischargeable by the Court. (Order Granting Plaintiff’s Motion

for Summary Judgment, Adv. Pro. No. 15-02049, Dkt. No. 14; Order Granting Plaintiff’s

Motion for Summary Judgment, Adv. Pro. No. 15-02050, Dkt. No. 14.) The Disbursing

Agent paid 74% of the Claims, and the Debtor will make payment of the remaining amount

of these nondischargeable claims. However, Scott and DeJesus continue to prosecute

certain appeals of the Judgment in Massachusetts seeking additional damages on a theory

not set forth in the Claims, which violate the Plan and the Confirmation Order. Despite

repeated demand, Scott and DeJesus refuse to dismiss these appeals, and the Debtor intends

to take appropriate action to enforce the Plan and Confirmation Order in this Court.

b. Jackson v. Reed Smith LLP et al., Adv. Pro. 17-02005: The Debtor

commenced an action against Reed Smith, LLP (“Reed Smith”) and Peter Raymond

(“Raymond” and together with Reed Smith, the “Reed Smith Defendants”), seeking

damages for, inter alia, breach of fiduciary duty and malpractice. The Reed Smith

Defendants filed a Motion to Dismiss Adversary Proceeding [Adv. Pro. Dkt. No. 27] on

June 19, 2017, which was fully briefed on August 21, 2017, and is currently under

advisement.

c. Jackson v. GSO Business Management, LLC et al., Adv. Pro. 17-02068:

The Debtor commenced an adversary proceeding against GSO Business Management,

LLC (“GSO”) and its principals regarding, inter alia, GSO’s unauthorized payment of

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property of the estate to itself without approval of this Court and for its failure to advise

the Debtor of certain tax consequences, which resulted in an increased tax liability to the

Debtor. GSO has filed a third-party complaint against Neligan, LLP and Boulevard

Management, Inc., and a scheduling report is due on March 12, 2018.

d. Miscellaneous: Recent media reports have falsely stated that the Debtor

failed to disclose alleged interests that he had in the online cryptocurrency “bitcoin” to the

Bankruptcy Court. A declaration of the Debtor (the “Jackson Declaration”) addressing in

detail recent media reports regarding bitcoin is attached hereto as Exhibit C. By way of

summary, the Debtor has never owned, and does not now own, a bitcoin account or any

bitcoins, and to the best of his knowledge, none of his companies had a bitcoin account

from 2014 to the present. A third-party, Central Nervous, LLC d/b/a CNI Merchandising

(“Central Nervous”), however, managed the website of the Debtor’s entity G-Unit Records

from which albums and merchandise may be purchased, by among other things, bitcoin.

Although Central Nervous processed the online sales and accepted bitcoins as payment,

the bitcoins accepted were contemporaneously converted to U.S. dollars by another

independent third party, and it was the converted U.S. dollars, not bitcoins, that G-Unit

received. Attached to the Jackson Declaration as Exhibit A is a declaration from Charles

Edward Norton III, the managing member of Central Nervous, detailing all bitcoin

transactions regarding sales of the Debtor’s albums.

WHEREFORE, based on the foregoing the Debtor respectfully requests that the Court

schedule a status conference to discuss the issues set forth above and grant such other and further

relief as justice requires.

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Dated: February 23, 2018 Respectfully submitted,

ZEISLER & ZEISLER, P.C.

/s/ John L. Cesaroni


James Berman (ct06027)
John L. Cesaroni (ct29309)
10 Middle Street, 15th Floor
Bridgeport, Connecticut 06604
Tel.: (203) 368-4234
Fax: (203) 367-9778
jberman@zeislaw.com
jcesaroni@zeislaw.com

Counsel for the Debtor

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IN THE UNITED STATES BANKRUPTCY COURT


FOR THE DISTRICT OF CONNECTICUT
NEW HAVEN DIVISION

IN RE: : CHAPTER 11
:
CURTIS JAMES JACKSON, III, : CASE NO. 15-21233 (AMN)
:
DEBTOR. :

CERTIFICATE OF SERVICE

I, John L. Cesaroni, hereby certify that on the 23rd day of February, 2018, a copy of the

foregoing Motion to Schedule Status Conference, all exhibits thereto, and the proposed Order were

served via the Court’s electronic CM/ECF system on all parties and/or counsel of record.

CURTIS JAMES JACKSON, III

By: / s / John L. Cesaroni


John L. Cesaroni (ct29309)
Zeisler & Zeisler, P.C.
10 Middle Street, 15th Floor
Bridgeport, CT 06604
Tel. 203-368-4234
Fax 203-367-9678
Email: jcesaroni@zeislaw.com

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Information to identify the case:
Debtor 1 Curtis James Jackson, III Social Security number or ITIN xxx−xx−0616
First Name Middle Name Last Name EIN _ _−_ _ _ _ _ _ _
Debtor 2 Social Security number or ITIN _ _ _ _
First Name Middle Name Last Name
(Spouse, if filing)
EIN _ _−_ _ _ _ _ _ _
United States Bankruptcy Court District of Connecticut

Case number: 15−21233 amn

Order of Discharge 12/15

IT IS ORDERED: A discharge under 11 U.S.C. § 1141(d)(5) is granted to:

Curtis James Jackson, III

By the court: Ann M. Nevins


2/2/17 United States Bankruptcy Judge

Explanation of Bankruptcy Discharge in an Individual Chapter 11 Case

This order does not close or dismiss the case. Most debts are discharged
Most debts are covered by the discharge, but not
Creditors cannot collect discharged debts all. Generally, a discharge removes the debtors'
personal liability for debts provided for by the
This order means that no one may make any chapter 11 plan.
attempt to collect a discharged debt from the
debtors personally. For example, creditors In a case involving community property: Special
cannot sue, garnish wages, assert a deficiency, rules protect certain community property owned
or otherwise try to collect from the debtors by the debtor's spouse, even if that spouse did
personally on discharged debts. Creditors cannot not file a bankruptcy case.
contact the debtors by mail, phone, or otherwise
in any attempt to collect the debt personally.
Creditors who violate this order can be required Some debts are not discharged
to pay debtors damages and attorney's fees. Examples of debts that are not discharged are:
However, a creditor with a lien may enforce a
claim against the debtors' property subject to that ♦ debts that are domestic support
lien unless the lien was avoided or eliminated. obligations;
For example, a creditor may have the right to
foreclose a home mortgage or repossess an
automobile. ♦ debts for most student loans;

This order does not prevent debtors from paying


any debt voluntarily. 11 U.S.C. § 524(f). ♦ debts for most taxes;

♦ debts that the bankruptcy court has


decided or will decide are not discharged
in this bankruptcy case;
For more information, see page 2 >

Form 3180RI Individual Chapter 11 Discharge page 1


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♦ debts for most fines, penalties, In addition, this discharge does not stop
forfeitures, or criminal restitution creditors from collecting from anyone else who is
obligations; also liable on the debt, such as an insurance
company or a person who cosigned or
guaranteed a loan.
♦ some debts which the debtors did not
properly list;
This information is only a general summary
of an individual chapter 11 discharge; some
♦ debts for certain types of loans owed to exceptions exist. Because the law is
pension, profit sharing, stock bonus, or complicated, you should consult an
retirement plans; and attorney to determine the exact effect of the
discharge in this case.
♦ debts for death or personal injury caused
by operating a vehicle while intoxicated.

Form 3180RI Individual Chapter 11 Discharge page 2


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Proposed Order Page 1 of 1

IN THE UNITED STATES BANKRUPTCY COURT


FOR THE DISTRICT OF CONNECTICUT
NEW HAVEN DIVISION

IN RE: : CHAPTER 11
:
CURTIS JAMES JACKSON, III, : CASE NO. 15-21233 (AMN)
:
DEBTOR. :
ORDER GRANTING MOTION TO SCHEDULE STATUS CONFERENCE

The Motion to Schedule Status Conference, filed by the debtor, Curtis James Jackson III,

having come before the court, and there being sufficient cause to grant the relief requested therein,

it is hereby

ORDERED that the Motion is granted; and it is further

ORDERED that a status conference in this case shall take place on ___________, 2018 at

____ am/pm at the United States Bankruptcy Court, Connecticut Financial Center, 157 Church

Street, 18th Floor, New Haven, CT 06510.