Representations included:

Individual and Corporate Debtors
Aram has represented a variety of high-income individuals, including business executives and insiders of insolvent corporations, real estate developers, physicians, and entertainment and sports industry members, in their pre-bankruptcy “workout” negotiations with creditors and in their later Chapter 11 reorganization cases when the “workout” process has failed. The following corporate debtors have recently been represented:

• In re Hi-Five Industries, LLC, In re One South Lake Street, LLC, and Wild Game Ng, LLC – these consolidated Chapter 11 cases concern the reorganization of the Siena Hotel Casino & Spa located in Reno, Nevada. Representation included the operations of the businesses in Chapter 11, including post-petition financing and cash collateral matters, and the ultimate sale of the businesses at an auction.
• In re S-King Estates, LLC – a Chapter 11 case pending in the District of Utah wherein the debtor owned a well-recognized 53-acre “ski-in / ski-out” property.  Representation included the successful confirmation of a “new equity” plan of reorganization and the restructuring of large secured creditor notes, trust deed, and personal guarantee.
• In re Wall Street Mart, L.P. – a large real estate Chapter 11 reorganization concerning the debtor’s interest in several valuable ground leases. Representation includes a plan of reorganization and an adversary proceeding to avoid and recover as a fraudulent transfer a multimillion dollar deed.
• In re Citizen Smith, LLC – successor insolvency and restructuring counsel for popular restaurant and nightclub located in Hollywood, California. Representation included rejection of existing agreement with operator of business, approval of post-petition debtor-in-possession financing and operating agreement, and limited liability company governance matters.
• In re St. Patricks Day Lease, LLC – counsel to Chapter 11 debtor with valuable commercial real property in Inglewood, California. Successfully prosecuted a sale of the real property and later litigated lien avoidance actions against a secured creditor to pay creditors in full and make a distribution to equity holders.
• In re 3-Day Blinds, Inc. – served as special labor and employment counsel to the Chapter 11 debtor-in-possession and protected the interests of employees of the company during business sale and transition periods.
• In re Morpho Technologies, Inc. – a technology company with valuable patent and intellectual property assets which were sold allowing for a near 100% distribution to creditors.
• In re USA eChambers – a national chamber of commerce business endorsed by the federal government.
• In re ABEX, Corporation & ABEX, LLC – a gold bullion exchange business.
• In re ABC Windows, Inc. – manufacturer and installer of custom windows for residential homes.
• In re Universal Unlimited Services, Inc. – provider of skilled medical diagnostic technicians.
• In re Xero Mobile, Inc. – a mobile solutions startup company.

Bankruptcy Litigation
Aram has bankruptcy litigation experience in a wide array of matters, including assumption and rejection battles for unexpired leases, executory contracts, personal services contracts, preference and fraudulent transfer avoidance, and objection to discharge prosecution and defense work.

• In re NGTV, Inc. – counsel to Chapter 11 and Chapter 7 trustee for Internet content and production company. Analyze and recovery various tangible and intangible assets and sell estate assets.
• In re Amir-Jahed – lead trial counsel for trustee; obtained judgment at trial for avoidance and recovery of transfers of multimillion dollar real property assets.
• In re Victor Ortiz – lead trial and appellate counsel for profession boxer; obtained declaratory judgment and injunction rejecting and terminating personal services contract.
• In re Noodles, Inc. – counsel to Chapter 7 trustee in avoidance and recovery of fraudulent transfers of restaurant related assets to insiders of business.
• In re Reliant Pictures, LLC – counsel to Chapter 7 trustee; sold valuable intellectual property assets, including film rights and associated litigation rights.
• In re Bornstein – counsel to Chapter 11 trustee of individual debtor involved in the production and direction of feature films.
• Represent preference recovery defendants in various pending bankruptcy cases across the country, including in In re Axium, In re Delphi, In re Placer Fire Equipment, Inc., and In re North General Hospital.

Official Committee of Unsecured Creditors’ Committee Representation
Aram represented creditors’ committees from a variety of industries, including:

• In re Scour, Inc. – music file-sharing company like Napster; instrumental in sale of business for ultimate 100% distribution to all unsecured creditors.
• In re Jill Kelly Productions, Inc. – well-known adult movie production and distribution company; obtained reduction of secured lien on assets and sold movie titles at court auction to generate unexpected recovery for unsecured creditors; proposed and confirmed a plan of reorganization after prosecuting various litigation rights, including executory contract assumption and rejection matters.
• In re InternetConnect, Inc., In re Flashcom, Inc., and In re Fastpoint Communications, Inc. – DSL companies for retail customers; aided in limiting scope and extent of secured liens and subsequent sale of businesses; lead counsel for recovery of avoidable insider and non-insider preference and fraudulent transfers.
• In re Dilip Ram – real estate developer with large number of interests in various real property LLCs and “single purpose entities” and personal guaranty liability in the hundreds of millions of dollars. Drafted joint Chapter 11 disclosure statement and plan of reorganization with the debtor and resolved various tax related matters to ensure a distribution to trade creditors.
• In re Ethos Design, LLC / In re Lounge 22, Inc. – represent joint creditors’ committee for companies that design, manufacture, and sell or lease high-end furniture used in large events or conferences such as the Academy Awards and other such productions. Resolved various cash collateral usage issues with the companies’ secured creditor to allow the businesses to continue operations for the benefit of creditors and subsequently aided in the sale of the businesses to maximize distributions for creditors.
• In re Centerstone Diamonds, Inc. / In re Michael Beaudry, Inc. – represent joint creditors’ committee for “jeweler to the stars” in the restructuring of the design and retail sale companies. Monitored business operations to protect valuable inventory and conducted investigations regarding inter-company and other insiders transfers.
• In re Broadcast Store, Inc. – video equipment sale and rental company; aided in confirmation of joint plan of reorganization.
• In re Aesthetic Frame & Art Services, Inc. – family run framing company; investigated propriety of financial transactions by insiders of business.
• In re Netter Digital Entertainment, Inc. – technology company specializing in movie industry; aided committee in the investigation of suspicious transactions among the insiders of the business.
• In re Pull’R Holdings, LLC. and Maasdam Pow’R Pull, Inc. – established hand tool manufacturer and distributor; successfully obtained unexpected “carve-out” for unsecured creditors from collateral of under-secured creditors.
• In re Energy Development Corporation and In re Steven Harris – oil producer in Huntington Beach, California; represented committee in operating Chapter 11 case and interface with Chapter 11 trustee to effectuate bankruptcy exit with favorable distribution for unsecured creditors.

Secured Creditor Representation
Aram has substantial experience representing secured creditors, both senior and junior priority secured creditors, in liquidation and reorganization proceedings. He has represented a national bank in consumer bankruptcy cases to obtain relief from the automatic stay and in reorganization matters for the bank’s commercial leasing subsidiary to protect collateral and related rights. Also, Aram has represented a large regional construction lender with $18 million at stake in its dispute with various mechanics’ lien creditors stemming from a failed senior housing project now in an involuntary bankruptcy case as well as the senior secured creditor in an urban clothing and sports equipment retail business.

Insolvency Counseling, Distressed Transaction, and “Workouts”
Aram has represented potential debtors and creditors in all stages of pre-bankruptcy, out of court workout transactions, including aiding in the restructuring of corporate capital and debt structures. These engagements have included a large furniture manufacturer, a busy overnight-type courier service, a multistate franchisee of fast food restaurants, and various distressed real estate developers.

Bankruptcy Asset Acquisitions
Aram has represented asset purchasers, both “stalking horse” and over-bidders, to aid in their purchases of commercial and residential real estate, high-tech assets, corporate shells, and going concern assets from several bankruptcy courts across the country. This has included the documentation of the underlying transaction, participating in contested sale matters, and the presentation of alternative plans of reorganization to implement asset acquisition goals for clients.

Reported Cases

• Top Rank, Inc. v. Victor M. Ortiz (In re Ortiz), 400 B.R. 755 (C.D. Cal. 2009).
• In re Lincoln Hospital Medical Center, Inc., 234 Fed.Appx. 426 (9th Cir. 2007).
• Investors Thrift v. Tam Ly Lam (In re Lam), 192 F.3d 1309 (9th Cir. 1999).