MOTION FOR (I) APPROVAL OF DISPOSAL OF RESIDUAL ASSETS (II) APPROVAL OF FINAL ACCOUNTING AND (III) ENTRY OF FINAL DECREE

1. Doug Skierski
Texas Bar No. 24008046
Skierski Jain PLLC
400 N. Saint Paul, Suite 510
Dallas, TX 75201
DSkierski@SkiJain.com
(214) 446-0332
(214) 446-0322 (facsimile)
Counsel for Matthew Orwig, Liquidating Trustee
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
IN RE:
§
FIRSTPLUS FINANCIAL GROUP. INC., § Case No. 09-33918-hdh-11
§
DEBTOR §
§
MOTION FOR (I) APPROVAL OF DISPOSAL OF RESIDUAL ASSETS (II)
APPROVAL OF FINAL ACCOUNTING AND (III) ENTRY OF FINAL DECREE
TO THE HONORABLE HARLIN D. HALE,
UNITED STATES BANKRUPTCY JUDGE:
COMES NOW, Matthew D. Orwig, in his capacity as the Trustee (the “Trustee”) for the
FPFG Liquidating Trust (the “Trust”) and files this Motion for (I) Approval of Disposal of
Residual Assets (II) Approval of Final Accounting and (III) Entry of Final Decree, in support of
which he would show as follows:
BACKGROUND FACTS
1. On February 7, 2012, the Court entered its Order Confirming Trustee’s First
Amended Plan of Liquidation for FirstPlus Financial Group, Inc. [Dckt. No. 770]. The Plan
Effective Date was February 22, 2012. [Dckt. No 789]. The Plan and Trust Agreement provide
that Trustee the authority to do all things and take all actions necessary to administer the Trust
without need for Court approval. The Trustee has nonetheless given creditors notice and sought
the Court’s approval of certain significant events, such as those addressed herein.
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2. MOTION FOR FINAL DECREE 2
2. The Trustee has served as Trustee since the creation of the Trust and has
administered the funds received by the Trust as set forth in the regular reports he has caused to
be filed with the Court.
3. The Trustee had made every effort to wind up the affairs of the Trust to allow
closure of the case. The Trustee will have arranged for all of the necessary steps to be taken by
the end of December 2020 and seeks an order closing the case effective at 11:59 p.m. on
December 31, 2020. As further detailed below, the remaining items to be done are as follows: (i)
two tax returns to be filed in the second quarter of 2021; (ii) a final quarterly payment to the US
Trustee, to be made in the first quarter of 2021; (iii) moving the Trust’s remaining documents
and records to storage (and pre-paying for 5 years of storage and destruction at the end of that
period); (iv) paying the Trustee’s commission (the Trustee has taken no payment during the
eleven and one-half years of this case); (v) pre-paying the Trustee’s counsel and accountants for
work anticipated in 2021 (and beyond) to close out the estate’s affairs; (vi) distributing the
remaining cash in the estate to a Dallas-area 501(c)(3); and (vii) selling the rights to any future
payments to a creditor.
Sale of the remaining assets
4. After a case concludes, the rights to any remaining assets are often sold to a third
party. Such sales promote efficiency and certainty by creating an owner for otherwise orphaned
funds that often come in after a case is closed. Terry Allen, a creditor and party in interest in the
case, seeks to buy whatever assets may remain from the Trustee for $6,000.00. The Trustee
(through counsel) has approached two organizations which buy remnants in bankruptcy cases
about buying the remnants of this estate. Both have declined to make an offer in excess of the
$6,000.00 offered by Terry Allen, a creditor in this case.
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3. MOTION FOR FINAL DECREE 3
5. The assets being purchased do not include any cash remaining in the estate’s
accounts, the documents belonging to the Trust, or any confidentiality or privileges belonging to
the Trustee or the Trust. The Trustee is only aware of one potential source of funds that could
come into the estate. A restitution order entered by the United States District Court for the
District of New Jersey in a related criminal proceeding calls for $14,000,000 in restitution to be
paid. Any restitution funds received have been directed to the Trust. However, in the four years
since entry of the restitution order the Trustee has received less than $5,000. Most of the parties
subject to the restitution order are in jail and likely will be for a significant period of time. The
Trustee believes the restitution order is unlikely to generate significant income and that any
income it does generate will not be sufficient to justify this case remaining open.
6. Under the circumstances, the Trustee believes it is in the best interest of the estate
to sell the remnants to Mr. Allen for $6,000, which was the highest and best bid received for said
assets. The Trustee therefore requests that the Court enter an order approving the sale of the
remnants to Mr. Allen.
Remaining Trust and Estate Funds and Trustee’s Compensation
7. To date, the Trustee has distributed or will distribute approximately
$9,990,468.00. His commission is approximately $323,144.04, calculated pursuant to 11
U.S.C. § 326 as follows:
$5,000 x 25% = $1,250
$45,000 x 10.5% = $4,500.00
$950,000 x 5% = $47,500.00
$8,990,468 x 3% = $269,894.04
Total $323,144.04
8. The remaining balance in the estate’s account is approximately $411,745.
9. The Trustee estimates that the remaining funds will be distributed approximately
as follows:
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4. MOTION FOR FINAL DECREE 4
Trustee’s Commission: ($323,144) (calculated pursuant to11 U.S.C. § 326)
5 years’ storage (estimated): ($5,000) (estimated)
UST Quarterly fee: ($4,875.00)
Estimated taxes: ($500.00). (NV - $500, U.S. - $0)
Accountants’ fees ($25,000)
Attorneys’ fees1
($15,000)
Funds from Mr. Allen $6,000.00
Remaining balance $44,226.00 (approximate)
10. Further administration of the remaining balance would be a burden on the estate
because the administrative costs to distribute exceeds the amount at issue.
11. The Trustee therefore intends to abandon the funds and to distribute such funds to
Youth180, a Dallas-area 501(c)(3) charitable organization which is an outpatient treatment
center for at risk youth, focusing on working with adolescents with substance use issues and
their families.2
12. The Trustee requests that the Court enter an order approving the disbursements
described herein, including the calculation of the Trustee’s compensation.
Closing the case and terminating the Trust
13. Having collected, disbursed and otherwise disposed of the remaining assets of the
estate, the Trustee submits that the case will be ready to be closed by December 31, 2020. That
said, the Trustee will need to sign a pair of tax returns in early 2021 and may have to sign
additional documents to close out the Trust. Accordingly, the Trustee respectfully requests that
the Court enter an order closing this case effective at 11:59 p.m. on December 31, 2020 and
preserving the Trustee’s authority to sign whatever documents may be necessary or desirable to
wind up and terminate the Trust, including any necessary tax filings.
1
The Attorneys’ fees include unpaid balances from 2020 and estimated future fees for dealing with case-related
matters post-2020.
2
More information on Youth180 is available at www.Youth180tx.org.
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5. MOTION FOR FINAL DECREE 5
REQUEST FOR RELIEF
Based on the foregoing, the Trustee respectfully requests that the Court (a) authorizing
the sale of the remaining assets to Mr. Allen; approving the disbursements described herein,
including the calculation of the Trustee’s commission; and (c) closing the case effective
December 31, 2020, but preserving the Trustee’s authority to sign any documents necessary to
satisfy the trust’s final obligations and terminate the Trust.
Dated this 8th
day of December, 2020
Respectfully submitted,
SKIERSKI JAIN PLLC
By: /s/ Doug Skierski
Doug Skierski
Texas Bar No. 24008046
DSkierski@SkiJain.com
400 N. Saint Paul, Suite 510
Dallas, Texas 75201
Tel: (214) 446-0332
Fax: (214) 446-0322
Counsel for Matthew D. Orwig, in his capacity as
Liquidating Trustee
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served by the Clerk of
Court upon all parties receiving notice through the Court’s CM/ECF system on December 8,
2020.
/s/ Doug Skierski
Doug Skierski
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