Dye v. Brown (In Re AFI Holding, Inc.)

355 B.R. 139, 2006 Bankr. LEXIS 3023, 47 Bankr. Ct. Dec. (CRR) 92, 2006 WL 3298337
CourtUnited States Bankruptcy Appellate Panel for the Ninth Circuit
DecidedOctober 25, 2006
DocketBAP No. CG-05-1247-MaPaK, Bankruptcy No. LA 01-41567-VZ
StatusPublished
Cited by27 cases

This text of 355 B.R. 139 (Dye v. Brown (In Re AFI Holding, Inc.)) is published on Counsel Stack Legal Research, covering United States Bankruptcy Appellate Panel for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dye v. Brown (In Re AFI Holding, Inc.), 355 B.R. 139, 2006 Bankr. LEXIS 3023, 47 Bankr. Ct. Dec. (CRR) 92, 2006 WL 3298337 (bap9 2006).

Opinion

OPINION

MARLAR, Bankruptcy Judge.

INTRODUCTION

The chapter 7 1 trustee has appealed the bankruptcy court’s order of removal, which found that she was not disinterested due to a material conflict of interest. She contends that the bankruptcy court applied an incorrect legal standard under § 324, and challenges the court’s findings.

We hold that the bankruptcy court properly applied a totality-of-cireumstances test in making its determination that the trustee’s prior connections with insiders negatively impacted the administration of the estate. Since disinterestedness is a requirement for service as an appointed trustee, see §§ 321(a)(1) and 701(a)(1), the court’s determination that lack of such disinterestedness was a “cause” for her removal was a proper exercise of its broad discretion under § 324. In addition, the evidence of an “appearance of impropriety,” as well as the trustee’s failure to disclose all of her connections, were factors contributing to a lack of creditor confidence and, thus, supported the bankruptcy court’s conclusion that cause for removal existed under § 324. Therefore, we AFFIRM.

FACTS

This case was commenced on October 21, 2001, by the simultaneous filing of six chapter 11 bankruptcy petitions. Advance Finance, Inc. and AFI Holding, Inc. were the general partners (together “AFI”) of four limited partnerships (together “AFI Entities”). The bankruptcy cases were consolidated, with AFI Holding as the consolidated debtor.

Richard Cohen (“Cohen”) was AFI’s president from 1994 to 1996. In July of 1996, Gary A. Eisenberg (“Eisenberg”) *143 was chairman of AFI and formed AFI Holding. The AFI Entities had been involved in a “Ponzi” scheme, specifically a “factoring” business whereby they would make loans to clients (borrowers) using the clients’ accounts receivable as collateral. Then, instead of paying the investors with the profits, they paid the old investors purported interest payments using the new investors’ money. Cohen left AFI in 1996, was criminally prosecuted, and went to prison. After filing the chapter 11 petitions, Eisenberg relinquished control of the AFI Entities and was convicted of securities violations.

The bankruptcy court ordered that a chapter 11 trustee be appointed for each case, and the U.S. Trustee selected Carolyn A. Dye (“Dye”). Since 1998, Dye had been “Of Counsel” to Weinstein, Eisen & Weiss, P.C. Some of Dye’s prepetition services are pertinent to this appeal, including her representation of and acquaintance with James Meister (“Meister”) and Allan Eriksen (“Eriksen”).

Dye’s Representation of Meister

In 1995, while Meister was employed as the controller of AFI, he hired Dye to represent him in a personal bankruptcy case. After that, Meister and Dye occasionally saw each other at social events but were not “close friends.” Dep. of Dye 89, Feb. 11, 2005.

When Eisenberg formed AFI Holding, Meister was named its chief financial officer, secretary, and director, but he was never an investor, creditor or equity shareholder in any AFI Entity. During Meis-ter’s employment with AFI, his domestic partner, Eriksen, invested money in an AFI entity.

Between 1996 and 1997, Meister became aware of fraudulent activities by Cohen and the complicity of Eisenberg. Specifically, he realized that his financial statements were inaccurate because they were based on forged documents, that money was being embezzled by Cohen, that Cohen was directing him to prepare false reports under threat of loss of his job, and that Eisenberg was requiring him to participate in new investment activities — “new money to pay repay the old money.” Dep. of Meister 56, Feb. 24, 2005.

Eisenberg, on the other hand, believed that Meister was intentionally engaged in corporate misconduct. See Dep. of Eisen-berg 24, Feb. 15, 2005. In a 1998 state court action against it, AFI filed a cross-complaint against Meister, which was subsequently dismissed. See Decl. of Loeb ¶ 3-4, Apr. 14, 2005.

Meister testified that his next communication with Dye, following his bankruptcy case, was in 1997 when he sought her advice concerning his decision to resign from AFI. However, he rescinded that testimony in a declaration dated April 13, 2005, in which he averred that his discussion with Dye had actually taken place in 1999, and concerned a termination notice which he had received from his subsequent employer, Tri-Capital Finance Corp. (“Tri-Capital”). 2 Meister resigned from AFI in June, 1997, but remained in a consulting role for another month.

In mid-1998, Meister referred Eriksen to Dye to represent him in seeking a withdrawal of his investment monies from AFI. Both Meister and Dye testified that they *144 did not speak to each other about either Ericksen’s legal matters or AFI.

Then, in September, 1999, Meister sought Dye’s legal advice regarding the Tri-Capital termination notice. Dye testified that she “looked [the notice] over only briefly, found it unremarkable, and had no other involvement with Meister.” Decl. of Dye 27, ¶ 9, Apr. 13, 2005.

Dye’s Representation of Eriksen

As a result of his investment, Eriksen was a limited partner in an AFI entity. Eriksen was privy to the misconduct at AFI because Meister had told him about it. See Dep. of Meister 63, Feb. 24, 2005. (Eriksen’s deposition testimony was stricken by the bankruptcy court as untimely, and that ruling has not been challenged in this appeal.)

In June, 1998, Eriksen hired Dye to assist him in his efforts to withdraw his investment monies. Eisenberg allegedly had told Eriksen that AFI needed to obtain new investor money in order to pay him. See Dep. of Meister 57-60. Eisen-berg also testified that he told Dye that Meister’s alleged misconduct was a reason not to pay Eriksen. Dep. of Eisenberg 40-41.

However, when Dye was questioned as to whether Eisenberg had ever implicated Meister to her in regards to operational misconduct, she stated that “he never mentioned Mr. Meister as being involved.” Dep. of Dye 94. And, when Dye was asked whether Eriksen had said anything to her “indicating that he thought there was financial misconduct” at AFI, Dye gave a cautious response:

Mr. Eriksen was a limited partner. He had no knowledge of what was going on in the office, particularly as it related to Mr. Eisenberg’s dealings with limited partners.

Id.

Dye then negotiated a deal with Eisen-berg to convert Eriksen’s equity to debt, 3 and Eriksen was given a promissory note, dated August 31, 1998, for $52,327.29 payable from AFI. This amount was compromised and satisfied in May 1999, at which time a “Release Agreement” was purportedly signed. (Dye provided a copy of an unsigned, undated “release agreement” but the signed document was never produced.) However, a letter from Dye to Eisenberg, dated May 18, 1999, was admitted into evidence, in which she stated:

Mr.

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Bluebook (online)
355 B.R. 139, 2006 Bankr. LEXIS 3023, 47 Bankr. Ct. Dec. (CRR) 92, 2006 WL 3298337, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dye-v-brown-in-re-afi-holding-inc-bap9-2006.