Acis Capital Management, L.P. v. Simek

CourtUnited States Bankruptcy Court, N.D. Texas
DecidedApril 24, 2025
Docket20-03060
StatusUnknown

This text of Acis Capital Management, L.P. v. Simek (Acis Capital Management, L.P. v. Simek) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Acis Capital Management, L.P. v. Simek, (Tex. 2025).

Opinion

IR SB» SN CLERK, U.S. BANKRUPTCY COURT Se wo ® NORTHERN DISTRICT OF TEXAS el ~ SSP \V/VEB 4 = wae © ENTERED SP As) THE DATE OF ENTRY IS ON Als "AY THE COURT’S DOCKET ‘Ys OY The following constitutes the ruling of the court and has the force and effect therein described.

Signed April 24, 2025 rd United States Bankruptcy Judge IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION IN RE: § Bankr. Case No. 18-30264—-sgj11 ACIS CAPITAL MANAGEMENT LP, et al., § Reorganized Debtors. § ACIS CAPITAL MANAGEMENT LP, et § al., § Plaintiffs, § § Vv. § Adv. Proc. No. 20-3059 § DAVID SIMEK, § § Defendant. §

MEMORANDUM OPINION AND ORDER GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT UNDER FED. R. CIV. P. 56 [DE #71 & 72]! I. INTRODUCTION The above-referenced post-confirmation adversary proceeding was filed on April 9, 2020, seeking to avoid and recover $317,457.75 of prepetition payments made to an individual named

' All references herein to “DE #[__]’” refer to docket entries on the docket maintained by the Bankruptcy Clerk in the above-referenced adversary proceeding.

David Simek (“Simek” or “Defendant”), pursuant to Bankruptcy Code Sections 544,2 547, 548, and 550 (the “Avoidance Action”). The Avoidance Action was abated by agreement of the parties for a very long time (for more than two years—from February 5, 2021, to April 26, 2023). The Avoidance Action finally came before this court on the merits, through two motions filed by the

Defendant, in February 2025: (a) a Motion for Judgment on the Pleadings Pursuant to Fed. R. Civ. P. 12(c), with Brief in Support [DE ## 68 & 69] (“MJP”), and (b) a Motion for Summary Judgment Under Fed. R. Civ. P. 56, with Brief in Support [DE ## 71 & 72] (“MSJ”). The court held oral arguments on these motions on April 16, 2025. In their original complaint, Plaintiffs Acis Capital Management, L.P. and Acis Capital Management GP, LLC (collectively, “Plaintiffs,” “Acis,” or the “Reorganized Debtors”) sought to avoid 21 transfers made by Acis to Simek during the roughly one year before the Acis bankruptcy petition date—which was January 30, 2018 (“Petition Date”). Who is Simek? Simek is alleged to have been retained by Acis as a consultant, pursuant to a Consulting Agreement (the “Agreement”), executed on June 15, 2016, by Acis’s then-President, James Dondero (“Dondero”).

Acis argues that the Agreement was an overly generous deal that was vague and did not benefit Acis. Acis further contends that it was either meant to benefit an old friend of Dondero’s or maybe also meant to drain Acis of assets—at a time when Acis was in contentious litigation with Joshua Terry (“Terry”), who eventually obtained a multi-million-dollar arbitration award against Acis and forced Acis into bankruptcy. Specifically, Acis has sought to avoid: (a) four payments totaling $53.053.63 that Acis made to Simek, in the 90 days before the Petition Date (between November 1, 2017 and January 29, 2018) (the “Alleged Preference Payments”), pursuant to 11 U.S.C. § 547(b); and (b) 21 payments totaling $317,457.75 (four of these 21 payments were duplicative of

2 Utilizing T .B .&C .C §§ 24.005 and 24.006, commonly referred to as “TUFTA.” the Alleged Preference Payments) that Acis made to Simek from December of 2016 through December of 2017 (the “Alleged Fraudulent Transfer Payments”), pursuant to either 11 U.S.C. § 548 or pursuant to 11 U.S.C. § 544 and §§ 24.005 and 24.006 of TUFTA (in either case, under either an actual-intent-to-defraud theory or a constructive fraud theory).

Approximately four years after the Avoidance Action was commenced, Acis filed a Motion for Leave to File a First Amended Complaint, on March 19, 2024 [DE # 49] (“Rule 15 Motion”) seeking to “refine[] the Original Complaint’s damage calculation”—these were the odd and ambiguous words chosen by Plaintiff for wanting to, in fact, add 13 more payments, totaling another approximately $200,000, as additional Alleged Fraudulent Transfer Payments. The Rule 15 Motion also sought to plead, for the first time, that Simek was an “insider” under Section 101(31) of the Bankruptcy Code. The court denied the Rule 15 Motion, mostly because of the inexplicable delay in both the filing of the Rule 15 Motion (again, it was filed approximately four years after the Avoidance Action was filed), as well as another inexplicable delay in setting the Rule 15 Motion for a hearing (the Rule 15 Motion was finally set for a hearing approximately one

year after the Rule 15 Motion was filed—and only after a nudging of Plaintiff by the Defendant and the court for Acis to do so). See DE ## 74-76, 83-84 & 90. A hearing was held on Simek’s MJP and MSJ on April 16, 2025. At the hearing, the Plaintiffs announced that they were withdrawing their claims as to the Alleged Preference Payments (Count 1). Therefore, the issue before the court was whether it should grant judgment in Simek’s favor on the Alleged Fraudulent Transfer Payments (Counts 2-4) without the need for a trial. The court has concluded that the Defendant, Simek, is entitled to summary judgment without a trial. The MSJ is granted for the reasons set forth below.3 Because the court is granting the MSJ, the MJP is moot. II. JURISDICTION Bankruptcy subject-matter jurisdiction exists in this Avoidance Action pursuant to 28

U.S.C. § 1334. This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A) and (H), so this court has statutory authority to enter a final judgment. Moreover, the court has constitutional authority to enter a final judgment because the parties have consented to the same. Lastly, venue is proper in this court pursuant to 28 U.S.C. §§ 1408 and 1409. III. UNDISPUTED FACTS Acis was a registered investment adviser and a portfolio manager for certain structured investment products known as collateralized loan obligations ("CLOs"). Acis was part of a massive group of companies that were related to Dallas, Texas-based Highland Capital Management, L.P. (“Highland”). Dondero was president of both Acis and Highland for most of their existence. Acis managed CLOs through portfolio management agreements ("PMAs") and

sometimes managed other funds through investment management agreements. The source of Acis's revenue was fees payable to Acis pursuant to the PMAs (which were between Acis and the CLO issuers). Acis historically contracted out its operations to Highland pursuant to Shared Services Agreements and Sub-Advisory Agreements with Highland (pursuant to which Acis paid Highland fees). Terry, mentioned earlier, was the primary person who managed Acis’s CLOs until he was abruptly terminated by Dondero/Highland on June 9, 2016. Terry was technically an employee of Highland. He was also a 25% owner of Acis. Litigation and arbitration ensued soon after Terry’s

3 This Memorandum and Opinion constitutes the court’s reasons for granting the MSJ, as required by Fed. R. Civ. Proc. 56(a). termination. Terry eventually obtained a $7,949.749 arbitration award against Acis on October 20, 2017.

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Acis Capital Management, L.P. v. Simek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/acis-capital-management-lp-v-simek-txnb-2025.