In Re: Avianca Holdings S.A.

CourtDistrict Court, S.D. New York
DecidedOctober 3, 2024
Docket1:21-cv-10118
StatusUnknown

This text of In Re: Avianca Holdings S.A. (In Re: Avianca Holdings S.A.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re: Avianca Holdings S.A., (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------------- X : In re : : Case No. 20-11133 (MG) AVIANCA HOLDINGS S.A., et al., : Chapter 11 : Jointly Administered Debtors. : : --------------------------------------------------------- X : UDI BARUCH GUINDI, SOSHANA : BARUCH, HABIB MANN, GOLAN LP, and : ISAAK BARUCH, : : Appellants, : : 21-CV-10118 (VSB) - against - : : OPINION & ORDER AVIANCA HOLDINGS S.A. et al., : : Appellees. : : --------------------------------------------------------- X

Appearances:

Glen Bernard Lenihan Jonathan Austin Lynn Oved & Oved LLP New York, NY Counsel for Appellants

Benjamin Max Schak Dennis F. Dunne Evan R. Fleck Erin E. Dexter Millbank LLP New York, NY and Washington, DC Counsel for Appellees

VERNON S. BRODERICK, United States District Judge: This bankruptcy appeal arises out of the objections to the joint Chapter 11 plan of reorganization for the Debtors1 approved by the bankruptcy court (the “Plan”). Appellants,2 holders of notes issued prior to the initiation of Chapter 11 proceedings, argue that the bankruptcy court erred in finding that a pool of available collateral was insufficient to leave them with secured claims, and that the bankruptcy court erred in how it allowed for substantive consolidation of certain Debtors. They also argue that these errors led to a further error in how

the voting to accept the Plan was calculated. Because I find no reversible error in any of these areas, the bankruptcy court’s rejection of Appellants’ objections is AFFIRMED. Debtors’ motion to dismiss this appeal as equitably moot is thus DENIED as moot. Factual Background3 A. The 2023 Notes and Their Rights to the Shared Collateral Debtor Avianca Holdings S.A. (“AVH,” and collectively with all Debtors, “Avianca”) is the parent holding company of a large airline group in Latin America. (A-151.4) On May 10,

1 The Debtors in the underlying Chapter 11 bankruptcy action, and each Debtor’s federal tax identification number (to the extent applicable), are as follows: Avianca Holdings S.A. (N/A); Aero Transporte de Carga Unión, S.A. de C.V. (N/A); Aeroinversiones de Honduras, S.A. (N/A); Aerovías del Continente Americano S.A. Avianca (N/A); Airlease Holdings One Ltd. (N/A); America Central (Canada) Corp. (00-1071563); America Central Corp. (65- 0444665); AV International Holdco S.A. (N/A); AV International Holdings S.A. (N/A); AV International Investments S.A. (N/A); AV International Ventures S.A. (N/A); AV Investments One Colombia S.A.S. (N/A); AV Investments Two Colombia S.A.S. (N/A); AV Loyalty Bermuda Ltd. (N/A); AV Taca International Holdco S.A. (N/A); Aviacorp Enterprises S.A. (N/A); Avianca Costa Rica S.A. (N/A); Avianca Leasing, LLC (47-2628716); Avianca, Inc. (13-1868573); Avianca-Ecuador S.A. (N/A); Aviaservicios, S.A. (N/A); Aviateca, S.A. (N/A); Avifreight Holding Mexico, S.A.P.I. de C.V. (N/A); C.R. Int’l Enterprises, Inc. (59-2240957); Grupo Taca Holdings Limited (N/A); International Trade Marks Agency Inc. (N/A); Inversiones del Caribe, S.A. (N/A); Isleña de Inversiones, S.A. de C.V. (N/A); Latin Airways Corp. (N/A); Latin Logistics, LLC (41-2187926); Nicaragüense de Aviación, Sociedad Anónima (N/A); Regional Express Américas S.A.S. (N/A); Ronair N.V. (N/A); Servicio Terrestre, Aereo y Rampa S.A. (N/A); Servicios Aeroportuarios Integrados SAI S.A.S. (92-4006439); Taca de Honduras, S.A. de C.V. (N/A); Taca de México, S.A. (N/A); Taca International Airlines S.A. (N/A); Taca S.A. (N/A); Tampa Cargo S.A.S. (N/A); Technical and Training Services, S.A. de C.V. (N/A). The Debtors’ principal offices are located at Avenida Calle 26 # 59 – 15 Bogotá, Colombia. (A-14.) 2 Appellants are Udi Baruch Guindi, David Baruch, Soshana Baruch, Habib Mann, Golan LP, and Isaak Baruch. 3 The facts in this section are recited only to provide background information for this decision and are not intended to be, and should not be viewed as, findings of fact. 4 “A-__” refers to pages in Appellants’ Appendix. (Docs. 17-1–17-5.) 2020, in the wake of the COVID-19 pandemic, Avianca—which comprises 40 Debtors—filed the underlying Chapter 11 bankruptcy cases. (A-151–52.) Prior to filing for bankruptcy, AVH issued the “2023 Notes,” which are 9% senior secured notes in the total principal amount of $484,419,000. (A-154; A-531.) The 2023 Notes were secured with interests in a pool of assets owned by various of the Debtors known as the

“Shared Collateral,” and the 2023 Noteholders’ interests were to be represented by the “2023 Notes Indenture Trustee.” (A-158; A-444–48.) Because the Shared Collateral secured the interests of others in addition to the interests of the 2023 Noteholders, all 2023 Noteholders were party to a “Collateral Sharing Agreement” dated November 1, 2019, which delineated the relative rights of all parties with interest in the Shared Collateral. (A-158.) Appellants are holders of the 2023 Notes in the total amount of $8,250,000. (A-2549.) In order to raise money needed to run its business during the Chapter 11 cases, Avianca negotiated and reached agreement with a group of 2023 Noteholders (“Agreement 2023 Noteholders”). The Agreement 2023 Noteholders arranged for the 2023 Notes Indenture Trustee

to allow other liens to take seniority over the liens giving 2023 Noteholders rights to the Shared Collateral, and they agreed to provide last-resort security for at least $200 million of new debtor- in-possession (“DIP”) loans known as the “Tranche A DIP Loans.” (A-152; AA-9–10.5) On October 5, 2020, the bankruptcy court entered an order approving all of Avianca’s DIP financing (the “Final DIP Order”). (A-439.) In addition to the Tranche A DIP Loans, the Final DIP Order also approved a “convertible ‘Tranche B’ facility secured by the same pool of collateral” (the “Tranche B DIP Loans,” and together with the Tranche A DIP Loans, the “DIP Tranches”). (A-541; A-440.) The Tranche B DIP Loans gave Debtors the right, at their option,

5 “AA-__” refers to pages in Appellees’ Appendix. (Docs. 24-1–24-4.) to convert the Tranche B DIP Loans into equity in what was to become AVH’s successor entity. (A-161; A-2445.) Specifically, according to the terms governing Avianca’s exit from bankruptcy, Avianca had to either repay both DIP Tranches, or it had to repay the Tranche A DIP Loans; if it did not have enough money left to pay the Tranche B DIP Loans “in full in cash,” it had to exercise the conversion option and provide the holders of Tranche B DIP Loans

with equity in AVH’s successor. (A-2443–44; A-162–63 (“To emerge from Chapter 11, the Debtors must either (i) Pay the Tranche B DIP Facility Claims in full in cash . . . or (ii) equitize the Tranche B DIP Facility Claims pursuant to the terms set forth in the Final DIP Order.”).) The Final DIP Order granted liens to the DIP collateral agent, who was responsible to all DIP lenders, on all of the “DIP Collateral” as defined in the Final DIP Order. (A-159; A-459–61 (defining “DIP Collateral”).) Notably, this grant included liens on the Shared Collateral that were senior to the liens securing the 2023 Notes. (A-159.) The Final DIP Order also has a marshalling provision. This provision states that any “DIP Facility Claims”—which includes the DIP Tranches, (see A-61, 63)—must “be satisfied first from proceeds of the Shared Collateral

and second from proceeds of other DIP Collateral (whether or not an event of default or exercise of remedies has occurred).” (A-484 ¶ 28; A-159 ¶ 16.) In other words, the “DIP Facility Claims” had to be “satisfied from the Shared Collateral before the DIP Facility Claims [could] look to any other collateral.” (A-160.) No appeals or motions for relief from the Final DIP Order were filed. (A-152.) Once the Final DIP Order was entered, all 2023 Noteholders received a notice dated August 20, 2020 (the “Bondholder Roll-Up Notice”).

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In Re: Avianca Holdings S.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-avianca-holdings-sa-nysd-2024.