Representation of Chapter 11 debtor bank holding company

Representation of Chapter 11 debtor bank holding company in three-day evidentiary hearing on Plan Confirmation. Prior to the hearing, Brian drafted and filed a Motion in Limine seeking to bar the debtor’s secured lender, which asserted it was owed no less than $19 million, from presenting any evidence at the Confirmation Hearing. The Bankruptcy Court granted the extraordinary relief requested in the Motion in Limine and barred the secured lender from presenting any evidence at the Confirmation Hearing, which facilitated the confirmation of the debtor’s Plan of Reorganization and the debtor’s successful exit from its Chapter 11 case.