American court hearing recordings and interviews - Season 6. Episode 7. March 13, 2023. In re BlockFi Inc. et al., chapter 11 bankruptcy case no. 2022-19361, audio of hearing held in the BlockFi bankruptcy proceedings pending in New Jersey, USA #crypto

Episode Date: April 30, 2023

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Ready, Wendy? Okay. Good morning, everyone. This is Judge Kaplan, and we will be starting our hearings on BlockFi, Inc. and Al. And before I hear from Debtors Council, let me just make note. I anticipate this morning to be virtually all informational. No arguments are scheduled, but it's an important. opportunity to allow all parties to update the court and all parties in interest on where

matters stand and in that regard I did want to express my appreciation to the debtor and both the official and ad hoc committees on putting together a joint correspondence to stakeholders trying to their best in the in these trying times to update the parties on where matters stand to try to lessen the confusion that's out there. And I think it was a great first, a great step in that direction. Today, those in court will unfortunately not have the benefit of our technology in seeing who's on Zoom. Our screen is not working in that regard. However, we do have Zoom participants. uh i know approximately 120 or so at the moment uh for those who are on zoom who want to be heard

please just as always use the raise hand function uh i can certainly see you all and uh those in court will be able to hear you uh so at this juncture let me turn to debtors council miz o kke good morning your honor christina o kke of perklin and ellis on behalf of the debtors Your Honor, we wanted to provide just a brief update on the debtor's cash and the current situation. So, Your Honor, there have been a lot of reports of BlockFi's potential exposure to Silicon Valley Bank. We have been all over this situation, and the short answer is BlockFi is fine. We have access to cash to operate in the normal course, including paying our employees and vendors. and we expect to have access to 37 million of the 278 million at SVB later today.

Your Honor, the vast majority of the debtor's funds at SVB, approximately $236 million, are invested in highly rated money market funds. 50% is allocated to the BlackRock liquidity Fed Fund admin, and 50% is allocated to Morgan Stanley ILF government in-sell, both of which are invested in government securities with SBB acting as agent on behalf of BlockFi. Once we get access to those money market funds, we will work with the U.S. trustee and the committee

to make sure that we are in compliance with Section 345B. I know the U.S. trustee filed a motion on Friday, and we have every intention of compliance. with our obligations with respect to 345B. We want to thank the U.S. trustee and the committee who we have been in constant contact with as the SBB situation developed and over the weekend, and who we've continued to have productive conversations with leading up to this morning's hearing. So, Your Honor, the short answer, again, is we are fine.

There's nothing to be worried about here. And again, we thank the committee and the U.S. trustee for their cooperation in this matter. Once we have access to those funds and we determine next steps in terms of the bank account and making sure that we're protected and it's in a safe place, we will update the court. And I anticipate we'll have news on that, you know, within a week or so. Thank you. I appreciate that. I'm sure it's a significant sigh of relief to those who are listening who have an interest in the financial

wherewithal of the debtor and are relieved to know that it's not as desperate as it seemed probably to a lot of people in the room Thursday afternoon and Friday and during the weekend. And I do appreciate all counsel working together. In that regard, I know there's other matters on for today, but I would like to give the U.S. trustee an opportunity if they wish to weigh in on where we stand again to either supplement or to modify what's been placed on the record. Good morning, Your Honor. Thank you.

Jeff Sponder, together with Andy Vera, the United States Trustee and Lauren Bilski, all on behalf of Andy Verre, the United States Trustee. Your Honor, at all levels of the United States Trustee Program, we have been engaged to ensure the state funds are available and protected. We do appreciate the cooperation of all counsel in these cases. We have worked diligently with debtor and committee counsel throughout this case, and especially this weekend, and we'll continue to work with the debtors as they've become 345 compliant so that all the state funds will be protected. Thank you. Thank you. Would it be best to keep a date going to?

forward for these the compliance issues so that we can have a follow-up conference or if need be hearing your honor Jeff Bonder again from the U.S. trustee I think that would be appropriate I know counsel for the debtors in within a week so I don't know if we have a hearing scheduled let's see we do have we we have you all on for the 23rd So why don't we just carry the U.S. trustees' motion to that date? We could always adjust the schedule from there if we need more time. And obviously, again, my thanks to the U.S. trustee was able to put this matter on, get papers filed on short notice on Friday, and we were able to schedule the hearing

if there's a need to do that again. the court will make itself available, but otherwise we'll carry the U.S. trustees motion to 323 with two other matters that are on. Then let me, is there anyone else who wants to be heard on the cash management issues before we move on to other issues? I see no one, no hands raised. So let me again go to debtors' counsel. for the next matter. Thank you, Your Honor.

Christine O'Kike again, on behalf of the debtors. Your Honor, the next item on the agenda is a status update on the wallet withdrawal motion, which was filed at docket number 121. So last Wednesday, as Your Honor noted, the debtors filed a joint letter among the debtors, the committee, and the ad hoc committee of wallet holders to provide an update to BlockFi's clients with respect to BlockFi's request to return the digital assets in the wallet accounts as of the platform paused to their clients as soon as possible. The debtors understand that our clients want the wallet withdrawal motion resolved promptly,

and so do we. And we are actively working with the committee, the ad hoc committee, and deferred 1031 to achieve that goal. Your Honor, when we filed the wallet withdrawal motion, two things happened. First, the committee advised the debtors that it was supportive of returning some wallet holdings to clients, but only if blocked by clients with those wallet holdings, were not subject to potential avoidance claims or clawbacks.

Determining which clients might be subject to clawbacks is a very complex issue, and the debtors understand that the committee's diligence with respect to that is ongoing. Second, the members of the ad hoc committee and deferred 1031, who are blocked by clients who attempted to transfer digital assets from their interest-bearing accounts or BIAs to wallet after the platform pause, which was 850. You've finally broken loose from work. Three friends, one tea time, and then the text. Honey, there's water in the basement.

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Both the debtors and the committee dispute that position, but the ad hoc committee and deferred 1031 have the right to have their arguments heard before the court. The debtors have provided the ad hoc committee and deferred 1031 with a substantial amount of information. We responded to about 60 questions that they had with respect to the platform pause and actions that the debtors took to help resolve this issue. But the debtors understand that the ad hoc committee and deferred 1031's diligence also continues. There are no open diligence request from our perspective.

And to the extent that they do have additional diligence requests, we would ask that they provide them promptly. Your Honor, we've reserved time on the court's calendar on April 19th to resolve the issue of whether the attempted transfers of the ad hoc committee and deferred 1031 after the platform pause should be treated as wallet holdings as of the platform pause. We really view that as an initial issue that should be decided before you even get to the question of dealing with potential preferences for people who are in wallet. So we expect to go forward on April 19th absent a resolution or agreement between the parties

before then and we're happy to continue to work with the ad hoc group as well as defer 1031 to reach a consensual resolution so I believe that's number doc number 559 the pause motion so that's going to be our in essence that's going on the 19th to be argued unless there's a resolution correct your honor okay great so we will submit a supplemental briefing schedule to your honor We continue to have discussions with the committee, the ad hoc group, as well as defer 1031 on that schedule. All right. Great. Thank you.

Does the committee wish to be heard? Good morning, Your Honor. Kenneth Olladdened Brown-Brodnick for the committee. Just to reiterate, the committee does view it as important to return these funds to wallet holders as quickly as possible as soon as it can be determined by your honor or hopefully by agreement who the way. wallet holders are. Ms. O'Kiki mentioned the preference diligence. We fully expect that that will be done by April 19th. And the committee has completed its diligence into all of the actual issues surrounding

the issues to be decided on the 19th. And unless Your Honor has any other questions, thank you for your time. No, thank you. Thank you, Ms. Rolett. Ms. Kovsky, I see your hand raised. Thank you. I'm Deb Codd Scott's cover for the Ad Hoc Committee. I wanted to just clarify a couple of things for the record.

Younger's that he referred to my client's transfers of attempted transfers. Obviously we dispute that characterization. With respect to diligence, that remains ongoing. The debtors had answered some but not all of the questions that were posed to them. We appreciate that information that our diligence is ongoing. and we are attempting to work out a schedule that enables the ad hoc committee and the Pergton that we want to take appropriate discovery in order to be able to put all the facts before, Your Honor. And while we have reserved time on April 19th, the due the direct to seek an extension of that day should,

if it be necessary, it will refresh to complete our discovery. All right. I hear you. Obviously, with respect to outstanding discovery, I'll just ask that the council do their best to confer as quickly as possible so we can move the process and not have a hold up over discovery issues. All right. I don't see it. Mr. Stark? Thank you, Your Honor. I know that normally we handle each matter with one lawyer. But I want to be constructive. That's fine.

Thank you. It's very important to the committee that issues move along quickly and that this case moves along quickly. And this is an important issue. And I make, and I have absolute respect for the position Ms. Kavsky's raising. I just want to rise, put a stake in the ground for maybe reverse, come back to it at a different date. We want to move this issue along. So I know we got our diligence done quickly. She has a job to do, and I fully respect the job.

I just, if there are issues in terms of discovery, if there are issues in terms of diligence, let's learn about them now, let's obviate them now, so we can resolve this issue once and fall in due course, and due course being on the newer side, not the farther side. So that's all I wanted to say. No, I appreciate that, and I was going to follow up. I thank you. Let's follow up. I'd rather be that we have quick calls to resolve discovery issues in the short term.

the court will always make itself available for a call rather than we don't need motion practice we don't need letter writing as much as just reach out and we can talk about these issues all right thank you thank you mizkovsky uh all right i think uh mr canowitz we come we come to the emergent matter yes your honor may please the court richard canowitz of haines and boone co-coun for the debtors and debtors in possession Your Honor, I just wanted to give you a quick status of the emergent matters. There were a lot of things going on behind the scenes that I want you to be apprised of so that if and when we get in front of, Your Honor, you're not surprised. So, as you see, as you entered the order on Docket 61, we extended the time for Merrick's to move our answer to 5.1. Likewise, in Docket's number 60, we extended the pretrial conference date to April 19. expect that potentially to move it again. That was one of the matters I was going to raise.

It doesn't make much sense if we're extending the answer to 5-1. We were going to take it in chunks because, you know, tomorrow is a trial in the emergent bankruptcy case. Let me get to that point. So, you know, coming out of the hearing on January 9th, you directed us to file an amended complaint, and we worked on that. And the DOJ took interest in that and asked us for a copy, and we sent it to them.

And that took weeks of discussions with them. And coming out of their review, they said to us, you know, on certain terms, your amended complaint interferes with the criminal prosecution of Sam Beckman-Fried and other investigations and potential prosecutions. And that you also, by virtue of some of the issues raised in the adversary proceeding complaint, interfere with what they believe is the current civil and criminal forfeiture proceedings. we obviously looked at the law, we came to a conclusion, and the outcome of our discussions, because it's not an agreement with the DOJ, but you have discussions with the DOJ and they tell you what they think, and you decide what to do next. Well, what we decided to do is file the amended complaint, but then ask Your Honor to stay it, right? And go through those issues as to why it matters for us to file an amended complaint

and for us to stay at pending prosecution of San Banker-Fried and the civil and criminal forfeiture proceedings, which unfortunately will be many years down the road and occur in the Southern District in New York, if in fact we agree, and we looked at the law, that the Southern District in New York really has jurisdiction over the disputes, all of the disputes. We never got to that point of filing and seeking a stay

because emergent filed the bankruptcy. Right. So we have taken the next step, to move to dismiss the emerging bankruptcy case for a host of the reasons their public records. I don't need to argue them here or point them out. Obviously, we're raising two key issues, the good faith of that filing by the JPLs in Antigua, as well as the fact that the money has been and the assets have been seized. And if the government is right, and I believe who they are, then these disputes are not going to happen in any bankruptcy court.

But they're going to happen in the Southern District of New York at some time in the future. So we're going tomorrow and we're going to have a whole trial, witnesses, etc. We'll see what Judge Dorsey does. In the meantime, we are talking to the DOJ and emergent, and I believe the FDX is also involved because they've tried to intervene in our motion to dismiss. To see, maybe fiduciaries can come to the table and actually figure out the right path to not waste legal fees, estate resources, et cetera. I'm hopeful we get there.

If not, well, we'll have our trust. trial tomorrow and we'll proceed accordingly. The one thing that I want to put on the record that's crystal clear, Your Honor was very, very clear that you believe you have jurisdiction over the debtor's interest in the guarantee and pledge agreement and the shares to the extent now you have it or don't have it by virtue of the seizure. We're going to defend that jurisdiction and we're going to defend property of the estate no matter where it's litigated. And I just wanted to leave that on the record so that everyone is clear that we are vigilant in protecting what we believe are the

victims of the FTCS, and Bankman-Fried slash emergent fraud. Thank you, Mr. Kanaworth. Thank you. Appreciate the update. I don't see anybody on Zoom looking to comment further. I don't see any raised hands.

Let me just ask, with respect to that pretrial date, do you want to leave it on for now, or should I be moving it into May? We didn't have a May court hearing to suggest that. but once we do establish it, yes, we should make an application however you want it on the record like we did last, or in pleading like we did last time, to move it. But yes, it has to be moved pending what happens in emergent home-backercy case.

All right, we're going to get to scheduling. I have some suggested dates, and we'll talk about it before the end of the hearing this morning. Thank you, Your Honor. I'll see you the podium, Ms. Chavez. Good morning. Good morning, Your Honor, Jordan Chavez, with Haynes and Boone. behalf of the debtors just two procedural motions that are both uncontested that we wanted to take up with your honor today the first one is the motion we filed

to extend the removal deadline at docket number 500 which was followed by this sports bridge order at docket number 514 in that motion we're asking for an extension of the removal deadline to May 27th 2023 and we received no objections or informal comments to this motion or the proposed order so we would ask that your honor grant the motion and we will get with local consul to submit the proposed order to chambers. That's fine. I've gone through it. There are no issues with it. It'll market granted and will market order to be submitted.

Thank you, Your Honor. The second motion is the motion for the claims procedures that we filed at docket number 535, which is designed to streamline the claims reconciliation and objection process. The proposed order that we filed with the motion already incorporated the constructive comments that we received, from committee council and then we received some informal comments after filing the motion from ARCH which is the debt one of the debtors insurers and we filed a notice of revised proposed order for that at docket number 586 there were no additional comments and no other objections received and the only change that we reflected in the revised proposed order was we had a basis for an objection if the insurers were obligated to make the payment rather than the debtors and the

insurer understandably just wanted a clarification that that would only be after a determination by this court or another court of competent jurisdiction. So with that, I would ask Your Honor to grant the motion, and again, we will get with local counsel to submit the proposed order to chambers. I only had one question. I think it all makes sense and how it's laid out. Service of the omnibus objections, and we're relaxing our local and the federal rule as far as

grouping in hundreds and the like. But how is service being undertaken on an individual claimant? I thought I saw, read through it, and it referenced both mail and email. Can you be more specific as to how, what's the intention as far as service on the claimants? Yes, Your Honor. To the extent we have both mail and email information, we are having parole served them via both methods of process and so that would be the measure we would take here as well. Given the interim redaction order, we are serving them directly and trying to keep all of their personal information confidential while doing so. And I understood in reading through your also trying to make a point to the claimants

that they should in their responses respect the confidentiality as well and redaction. It may be that individuals need some assistance, and I think you included contact information as well, both at Crowell and at the firms, correct? Yes, Your Honor. We included my direct contact information as well as one of my colleagues, Mr. Zavala, so they can directly reach out to us if they can have questions or need assistance, and of course to hopefully and formally resolve the objections so we don't have to take up court time. I'm just judging from some of the email that my chambers receives from claimants. Unfortunately, the claimants tend to be more liberal or loose unintentionally with their own personal identifiable information. We end up sealing and redacting their information.

We're not putting on the docket to protect them. So it's a difficult issue, but I think the notices are there to admonish them to be careful on their own end. I don't have any other issues. Anyone in court have any issue on the objection claims procedure in motion? I know you've gone through with all the parties. I've seen no questions. So it'll be order to be submitted? Yes, Your Honor.

All right. Thank you. All right. That goes through, I think, what we had on our agenda. Oh, Mr. Stark? Yes. I wanted to spend a minute on something that Your Honor just touched upon, But Your Honor touched upon at the beginning of the hearing as well.

And I wanted to do something, Your Honor, will allow me. Sure. Your Honor, mentioned the letter that the debtors and the committee and others circulated to the customers. And, Your Honor, made reference again to the customer creditor outreches to the court, perhaps to chambers. I'd like to address that just for a moment if I can. We, as a committee, acknowledge not only to do that,

we have a statutory and fiduciary obligation to talk to customers and creditors in the normal case. This is not the normal case. Customers and creditors here lost their lives savings, lost their wages and they're worried, and we get that. We've been in existence, at least with professionals, for under three months. It seems like for the people who lost their money, that seems like an eternity and we're very sensitive to that. but for bankruptcy, there's a lot that has to go on in the initial stages of bankruptcy, and especially in a sensitive case, disables the kind of direct communication that I know folks are really thirsting for in need. We set up a website, we have a Twitter feed, but we acknowledge, and we have to acknowledge.

The number of inbound calls and emails that I know Your Honor's Chambers have been receiving, We want to put us off to that. We want to help the community more. The first thing I can do right now is on the record to those who are listening in, my name is Robert Stark. I work at a firm Brown-R-R-R-R-Rudnik. My email is R-Stark at Brown-Rudnik.com. My telephone number is 212-209-4862.

Any customer or creditor who is listening in who wants to find out information about this case, Please call or email me, and we will respond within 48 hours. It is not the court's job to respond. It is mine, and we will do that. The second thing that I can do, for Your Honor and for all those who are listening, the committee understands, and has spent an awful lot of time in the last two weeks specifically, to come forward with a program for reaching out to the customers and consumers. There are a whole host of different ways that we could try to do it, from town hall meetings to Reddit Q&As to inbounds and outflows.

We have to be thoughtful. We have to be disciplined. There's an awful lot going on. Again, it's a very sensitive case. We have our own confidentiality issues and fiduciary issues, but we know that there's more that we can be doing. And so we are right about to launch, but for the issues of last week. probably would have happened last week. We're about to launch a program where we're going to be much more communicative with the community outside,

and they will have much easier access to us. They will know our names. They will know that we're standing by. They will have information, much more information, but it won't be sensitive information that we believe might inhibit our ability to resolve this case quickly, but they will have greater understanding and less confusion. So that's about to get launched right now. I just want your honor and everyone listening to know that.

That's great. I appreciate that, Mr. Stark. I know my law clerks appreciate it. Reducing the burdens on the court, because we would just defer it to you all and send the names along. I think I look forward to the enhanced communication. I think it'll be worthwhile. I appreciate it.

Thank you. Let's talk about some calendar events. Yeah. Just one item to tag along. Sure. We appreciate the committee, and especially Mr. Stark, taking the laboring more on communicating with his constituency. But just so you know, we get daily inbound both at Haines and Boat and Kirkman and Ellis, and we respond by email, and we have a team working to get those creditors' information about the crawl website, the process for filing proofs of claim. So the debtors of state recognizes that this is a, I would say, a choppy process, but one that needs to have all resources devoted. so it's transparent and people have confidence that this case is moving forward and one day, you know, they will be taking care of as best we can.

No, I appreciate that. Appreciate the debtors' efforts. I just remark, the Chapter 11 process practice has certainly changed in a decade. The ability through the use of these claims agents, the websites, what I can't help but see and hear on YouTube and Twitter, So it changes the landscape, and I think for the better in transparency, even the ability to make our hearings available on Zoom. So I thank the professionals for their work. I know it's difficult given that these are personal. This impacts the lives of many.

Thank you. You're welcome. On behalf of the state and all the professionals, we do appreciate chambers dealing with these issues, and we're happy to be as responsible as you want us to be in connection with inbound to the court. Great. All right. Thank you. Thank you again.

So let me go through what I have coming up, and you can all correct me where we've missed something. Our next date is March 23rd. We have two matters that had been scheduled, the sale motion and the extension of time to assume or reject. I think that's 571 and 572. those are still scheduled for March 23rd. We have added the Carried Trustee 345 motion. The next date after that is April 19th, in which we have what I call the pause motion,

as well as the first, that's number 559, and the first omnibus claims objection motion that was filed. That's 573. And then there's another motion, Your Honor, where we're seeking to return the ACH payments that are held by scratch to customers in California. Correct. Oh, and then it's anticipated that that date will also be a motion for exclusivity to extend the debtors exclusivity. All right, so a motion for exclusive. We'll be filed in due course.

Those are all intended for 419. Correct. we have a date that I've converted to an omnibus date it was the date for the initial disclosure statement and disclosure statement hearing that's May 8th no we need May dates I just turned that May 8th date into an omnibus date

so that's available for parties and we have to place we have what I'll call the the redaction motions, including the confidential party. It's early on, number four on the docket, as well as, I believe, 127 confidential party status, and also I think redaction relative to Kroll, number 443, those three redaction motions, sealing motions, we need to put on a date. So we have now, we have 419, we have through 5-8,

and I can make two other dates available in May. Do you have a preference? I think May is fine. Then we'll carry those. Yeah, I could give you a status update as to the counterparty ceiling as well as the CIA redaction. There is a sponsor. There you are. Sneaking up on me.

Yeah. So the PIA redaction motion, obviously, a huge concern for not only the debtors but the committee as well as the ad hoc group who filed joiners. We'll try to have a discussion with the U.S. trustee to see if we could resolve it. If not, we are going to have to have a hearing. As to the counterparty redaction motion, what we agree to with the U.S. trustee for the adjournment is we'll take it in chunks, meaning once we have completed a sale and the counterparty disclosure is not any more prejudicial to the, to the estate and the process, will file supplemental retention, you know, declarations and all those things to make those disclosures.

The issue becomes, though, a lot of professionals who are going to file supplemental paper. So we've got to work out a process so that we don't have 20 filings for every minor transaction. So we've got to figure that one out, but that's our goal, on a rolling basis, to actually make those disclosures when they're not prejudicial to the estate. of the counterparties who are no longer vying for state assets in one way or another. So I think carrying it to the eighth

is important. That particular counterparty ceiling motion may get kicked again based on what's happening. And if we don't come to an agreement on the PIA redaction motion and whole or part, we're probably going to have to have a hearing on that. Fair enough. With witnesses.

Then docket number matters reflected by docket numbers 4-127 and 443 will be carried to 5-8 at 10 o'clock. And then as far as other May dates, I have, it probably doesn't make sense to have one a week later, 515. I have 515 and 529 available. I think we should hold the 529 just in paste.

Reserve it, because, you know, if I get booked, you know, future filings. It's Memorial Day. Your Honor, it's Memorial Day? Memorial Day? Not the problem? Well, hopefully I'll be on a golf course somewhere, but yes. Then, well, we could do 522 in the afternoon, or then the next Monday is 6-5, June 5th.

Trying to spread it out. Why don't we do 6-5 if we need to come back to court? Some of these hearings may very well be Zoom, as opposed to being in person while we like being in person to the extent we need really, we could always set something up. That's fine. And to the extent that emergent matters may arise, we'll schedule it either on my motion day, normal motion day, or as needed. Yeah, yeah. So just to bring something to the court's attention on the record, two class action complaints were filed.

some of which have been served. The debtor intends on filing today an adversary proceeding complaint seeking to stay those pending confirmation in the usual course under 105-362, and for all the arguments that have been made before we get to our complaint filed that others have made. We're going to reach out to the plaintiff firms

who started the class action lawsuits. There are two, one in Jersey, in the district court, and one in Massachusetts. And we are going to see if they will voluntarily stay these proceedings. whether we do it in chunks or whether we do it wholesale, we'll discuss it with them. But if they do not agree to avoid prejudice to the estate

in any defaults or admissions, which we believe is prejudicial, we will come before, Your Honor, seeking a TRO in first instance. So that might be later on this week, depending on how our discussions go. And we just wanted to alert, Your Honor, because we may be making that request, and then Your Honor could direct whether that be in person or by Zoom. All right, great. Then we'll see. there's a need and then we'll decide how to go about as far as the hearing I would

anticipate Zoom would make the most sense so are there any other matters that anyone wishes to raise mr. Sponder thank you your honor just wanted to piggyback off of mr. Stark's comments to customers and just set forth on the record also that if customers do receive correspondence requesting their personal information that they should reach out to the United States trustee's office great Thank you. Appreciate that as well. Quick question on the sale motion. Can we give a short update? Are we going forward with the motion? I don't know what transpired with the transaction. Yes, Your Honor. We do anticipate going forward with the motion, and to my knowledge, it will not be contested, but I don't believe the objection deadline has run. Okay. All right. Then we're good. I appreciate everybody's efforts.

uh... and reach out for chambers as the need arises otherwise be safe take care thank you thank you your honor word good goodbye okay great thank you thank you all