In re Financial Partners Class Action Litigation

73 B.R. 49, 1987 U.S. Dist. LEXIS 14062
CourtUnited States Bankruptcy Court, N.D. Illinois
DecidedMarch 31, 1987
DocketNo. 82 C 5910
StatusPublished

This text of 73 B.R. 49 (In re Financial Partners Class Action Litigation) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Financial Partners Class Action Litigation, 73 B.R. 49, 1987 U.S. Dist. LEXIS 14062 (Ill. 1987).

Opinion

MEMORANDUM DECISION

JOAN HUMPHREY LEFKOW, United States Magistrate.

This decision concerns two issues: (1) whether payments made to the bankruptcy trustee should be included as part of certain claimants’ losses in this action and (2) whether payments received as “interest” from the class action defendants should be deducted from losses incurred.

I. PAYMENTS TO TRUSTEE

The defendants, known in this securities fraud litigation as “Financial Partners,” were participants in an investment scheme which caused a loss to the plaintiff class of more than $25 million. Each class member invested money with the defendants and their investments were partially or totally lost as a result of the defendants’ conduct. Prior to the filing of this law suit, in the fall of 1982 certain Financial Partners defendants filed for bankruptcy. In the 90 days preceding the initiation of the bankruptcy proceeding, Financial Partners made payments to class members which were characterized either as a return of the investor’s principal or as interest payments. On October 29,1984, the bankruptcy trustee filed a number of bankruptcy preference actions against certain of the class members in order to recover for the bankrupt estates money that had been paid to them within 90 days of filing bankruptcy. Class counsel moved in this action to stay the prosecution of the preference ac[50]*50tions on the basis that they involved the same parties and at least one of the same issues, i.e., the fraudulent conversion of the class members’ monies. Class counsel asserted that it would be duplicative, expensive and would cause inordinate delay. Class counsel also argued that the money was not as a matter of law a preference and stated,

If this Court were to resolve the preference issue against the Class Members named as defendants in the bankruptcy preference action, then any money received by these Class Members as a preference could simply be deducted from any ultimate recovery of the Class Members in the class action proceeding. To pursue these preference actions in Bankruptcy Court would serve no purpose.

Emergency Motion for Order Regulating Conduct of Class Action. Docket entry no. 425, paragraph 13. The matter was resolved by agreement, however, and the bankruptcy preference actions proceeded. Order of November 20, 1984; docket entry no. 426. The outcome was that some of the defendants in the preference actions who are claimants in this action settled with the trustee and returned funds to the bankrupt estates. In some instances, the amount was as little as $500, but in others it was as much as $100,000 or more. These voidable preference actions increased the bankruptcy estates by approximately $500,000.

The claimants state that they settled based on the principle of Cunningham v. Brown, 265 U.S. 1, 44 S.Ct. 424, 68 L.Ed. 873 (1924) and Teletronics, Ltd. v. Kemp, 649 F.2d 1236 (7th Cir.1981), that where certain investors in a fraudulent scheme have managed to recoup their investments while other investors have lost, the investors who have benefitted at the expense of others must redeposit their funds so that all investors are ultimately treated in the same manner. The bankruptcy preference defendants maintain that they settled the preference actions in face of certain loss rather than litigate and incur a greater loss.

Through the prosecution of the pending litigation, plaintiffs’ counsel have established a settlement fund of approximately seven million dollars to be divided among all the investors who lost approximately $25 million. The principle governing distribution of the fund is that each investor should be paid a pro rata share of the principal amounts invested by each investor, which comes out to about 20-25 percent. In calculating a claimant’s loss, class counsel included all the payments the investor made to Financial Partners reduced by all payments the claimant received back from Financial Partners, whether designated as interest, principal or otherwise. Thus any payment a class member received in the 90 days prior to Financial Partners’ bankruptcy were subtracted from the total amount the class member paid to Financial Partners in calculating the loss. But if the claimant returned some of the money received from Financial Partners based on the preference action in the bankruptcy court, class counsel takes the position that that amount should not be added to the total principal lost by that claimant. As an example, if a claimant invested $10,000 and received an interest payment of $1,000 in August, 1982, class counsel would calculate that claimant’s loss as $9,000. If the investor paid $750 to settle the voidable preference action against him, the claimant would calculate the loss as $9,750. Class counsel, however, would not include this payment to the bankruptcy trustee in the loss calculations but would maintain the loss as $9,000.

Class counsel’s justification for this position is that these bankruptcy defendants chose to settle than to incur the expense of defending and perhaps defeating the trustee’s claim. Thus, other class members should not absorb the risk of their decision. Furthermore, class counsel argue, if these payments to the trustee are included in calculating the class losses, the distribution of the class fund will be delayed until the bankruptcy estates are closed. This is so because these claimants may receive a portion of the bankrupt estates and, if so, that amount should be subtracted from their loss calculation. Thus, the class fund could not be distributed until the trustee resolved all such voidable preference actions, paid all dividends to class members and was [51]*51ready to close the estate. They argue that the amount in question is not substantial enough to justify the delay and further complication that would result from including the voidable preference amounts. The $500,000 increase in the bankruptcy estates is only about 2 percent of the $25 million total losses for all class members. Thus, they argue, the additional expense incurred does not on the whole warrant delaying distribution from the class fund in order to finally ascertain the amounts due to these claimants. Finally, class counsel argue that their vigorous prosecution of this litigation created the settlement fund. The bankruptcy action is not related to the claims made in this litigation and the settlement fund in this litigation should not be used to compensate for every wrong that Financial Partners might have committed.

A number of claimants who made payments to the bankruptcy trustee vigorously oppose class counsel’s method of calculation. Certain of them point out that class counsel earlier took the position that the voidable preference actions were related to this action and should be stayed. They further argue that they had no viable chance of winning the voidable preference actions and therefore were compelled to settle in order to conserve their clients’ funds. Furthermore, they were under pressure to settle because they feared that this class litigation might be settled or tried before a decision against them in the voidable preference action and they might be in jeopardy of having no claim in either forum. Other claimants focus on the issue whether the distribution would truly have to be delayed until the bankruptcy estates are closed and whether any dividend from the bankruptcy estate should be deducted from the loss calculations.

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Related

Cunningham v. Brown
265 U.S. 1 (Supreme Court, 1924)
Heyman v. Kemp
649 F.2d 1236 (Seventh Circuit, 1981)

Cite This Page — Counsel Stack

Bluebook (online)
73 B.R. 49, 1987 U.S. Dist. LEXIS 14062, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-financial-partners-class-action-litigation-ilnb-1987.