TH PROPERTIES v. OFFICIAL COMMITTEE OF UNSECURED CREDITORS

CourtDistrict Court, E.D. Pennsylvania
DecidedMay 28, 2025
Docket2:24-cv-04143
StatusUnknown

This text of TH PROPERTIES v. OFFICIAL COMMITTEE OF UNSECURED CREDITORS (TH PROPERTIES v. OFFICIAL COMMITTEE OF UNSECURED CREDITORS) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
TH PROPERTIES v. OFFICIAL COMMITTEE OF UNSECURED CREDITORS, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

TH PROPERTIES; TH PROPERTIES, CIVIL ACTION LP; TH PROPERTIES OF NEW JERSEY, LP; TH PROPERTIES, INC.; TH PROPERTIES, LLC; MORGAN HILL DRIVE, LP; NORTHGATE DEVELOPMENT COMPANY, LP; and, WYNSTONE DEVELOPMENT GROUP, LP., Appellants, NO. 24-4143

v.

MONTGOMERY MCCRACKEN WALKER & RHOADS LLP, Appellee.

MEMORANDUM OPINION

Montgomery McCracken Walker & Rhoads LLP (“MMWR”), a law firm based in Philadelphia, represented TH Properties, L.P. and several other reorganized debtors (collectively, the “Reorganized Debtors”)1 in their Chapter 11 bankruptcy proceedings. A fee dispute regarding MMWR’s final fee application resulted in a stipulation (the “Stipulation”) between MMWR and the Reorganized Debtors regarding the amount due to the firm. Unfortunately, the Stipulation did not end that dispute. When the Reorganized Debtors submitted what they viewed as their final payment in satisfaction of their obligations under the Stipulation, MMWR filed a Motion to Enforce in the United States Bankruptcy Court for the Eastern District of Pennsylvania (the “Bankruptcy Court”), arguing that the Reorganized Debtors breached the terms of the agreement because they still owed the firm approximately $680,000. The Bankruptcy Court, in a July 29, 2024 Opinion and Order, granted MMWR’s Motion. This appeal followed.

1 The Reorganized Debtors are TH Properties; TH Properties, LP; TH Properties of New Jersey, LP; TH Properties, Inc.; TH Properties, LLC; Morgan Hill Drive, LP; Northgate Development Company, LP; and, Wynstone Development Group, LP. For the reasons set forth below, the Bankruptcy Court’s Opinion and Order shall be affirmed, and this action shall be remanded to the Bankruptcy Court for any further proceedings. I. BACKGROUND A. Factual Background In 2009, the Reorganized Debtors—several property development companies—filed for bankruptcy and retained MMWR as counsel. Over the next three years, MMWR represented the entities in their Chapter 11 proceedings, and, in so doing, filed nine interim applications for fees

and costs. In August 2012, MMWR submitted its tenth and final application (the “Final Fee Application”), which, after crediting $680,000 in payments that the Reorganized Debtors had already made to the firm, sought approximately $2.6 million in fees and costs.2 Shortly thereafter, however, the Reorganized Debtors retained new counsel and filed several objections to the Final Fee Application. They argued that the firm’s requested fees were excessive; that it had failed to adequately and efficiently handle their case; and, that the timing and manner of payment under the Chapter 11 reorganization plan was vague. To resolve that dispute, the Parties subsequently negotiated and entered into the Stipulation, which, of relevance here, included a provision that reduced the $2.6 million figure asserted in the Final Fee Application to $2.325 million. It stated:

MMWR will agree to reduce its total fee and cost claims against [the Reorganized Debtors] from $2.6 million for all pre-bankruptcy, bankruptcy, and post- bankruptcy work for [the Reorganized Debtors] to the total sum of $2.325 million, with the said reduction of $275,000 to be applied after receipt by MMWR of $2.325 million, thereby leaving unchanged the present agreed on base number of $2,537,683.40 for MMWR for purposes of calculating the proportional allocation of any future distributions to MMWR and other Plan creditors. And the said objections are hereby resolved and withdrawn with prejudice.

2 Initially, the Final Fee Application only credited $491,978.42 in payments that the Reorganized Debtors made to MMWR. But the firm subsequently verified the accuracy of the figures included therein and discovered that the Reorganized Debtors had, in fact, paid $680,000. The Reorganized Debtors were to generate the $2.325 million figure asserted in the Stipulation from, among other sources, the sale of residential lots in their developed or projected communities. The Bankruptcy Court approved the Stipulation in January 2013, after which the

Reorganized Debtors made several timely payments to MMWR in the ensuing years. Then, in February 2016, counsel for the Reorganized Debtors sent a letter to the firm enclosing what it characterized as a final payment in satisfaction of the Reorganized Debtors’ obligations under the Stipulation. The Reorganized Debtors posited that the plain language of the Stipulation— specifically, the clause pertaining to “total fee and cost claims . . . for all pre-bankruptcy, bankruptcy, and post-bankruptcy work”—contemplated that their prior payments of $680,000 to MMWR should be credited against the $2.325 million figure. B. Procedural History After receiving the Reorganized Debtors’ letter, MMWR disputed that it had been paid in full and filed Motions to Reopen the Bankruptcy Case and Enforce the Stipulation. In those Motions, and at oral argument before the Bankruptcy Court, MMWR asserted that the Parties

intended the $2.325 million figure referenced in the Stipulation to only cover outstanding payments at the time the Stipulation was executed—not payments already made by the Reorganized Debtors. So, according to MMWR, the Reorganized Debtors had not fulfilled their obligations because they should not have set off $680,000 against the $2.325 million figure agreed upon in the Stipulation. Thus, the firm asserted that the Reorganized Debtors still owed it $680,000. Following oral argument, the Bankruptcy Court granted MMWR’s Motion to Reopen the Bankruptcy Case “for the limited purpose of deciding a question of interpretation having to do with provisions of [the Stipulation].” It then determined that “the interpretation of the Parties’ agreement advanced by” the Reorganized Debtors “shall control for purposes of payment to MMWR for legal fees and costs” because it “accords with the terms of the parties’ Stipulation.” Thus, under that interpretation, the Reorganized Debtors had satisfied their obligations, as the Stipulation “expressly and unambiguously provide[s] that the payment of $2.325 million would

satisfy in full [their] liability to [MMWR] for all its legal fees and costs.” MMWR appealed that decision to this Court pursuant to 28 U.S.C. § 158(a)(1), arguing that the Stipulation was ambiguous. This Court affirmed the Bankruptcy Court’s decision, concluding that the terms did not suffer from any patent or latent ambiguities under Pennsylvania law. See Montgomery, McCracken, Walker & Rhoads, LLP v. H&K Grp., Inc., 2017 WL 1333243, at *2 (E.D. Pa. Mar. 24, 2017). Patent ambiguities are those that “appear[] on the face of the contract and [are] a result of defective or obscure language,” Krizovensky v. Krizovensky, 624 A.2d 638, 643 (Pa. Super. 1993) (citation omitted), while latent ambiguities “arise[] from extraneous or collateral facts which make the meaning of a written agreement uncertain although the language thereof, on its face, appears clear and unambiguous,” Duquesne Light Co. v.

Westinghouse Elec. Corp., 66 F.3d 604, 614 (3d Cir. 1995) (citation omitted). With respect to patent ambiguity, the Court found that the Stipulation contains “no defective, obscure, or indefinite language,” as it states “MMWR agrees to reduce its ‘total’ fee and cost claims from $2.6 million ‘for all pre-bankruptcy, bankruptcy, and post-bankruptcy work’ to the ‘total sum’ of $2.325 million.” Montgomery, McCracken, 2017 WL 1333243 at *3. That clause, the Court reasoned, demonstrated that the Stipulation “explicitly covers the payments [the Reorganized Debtors] made to MMWR prior to [its] execution[.]” Id.

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Bluebook (online)
TH PROPERTIES v. OFFICIAL COMMITTEE OF UNSECURED CREDITORS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/th-properties-v-official-committee-of-unsecured-creditors-paed-2025.