EFTA00807038Set 9
2017-08-0320p6,630w
Motion to Dismiss", and collectively with the Involuntary
Petitions, the "Involuntary Petition Contested Matter"). See Docket No. 46.
3. On June 30, 2017, the Debtors and the Lenders filed ... Page 4 of 20
regarding the discovery schedule relating, among others, to the Involuntary Petition Contested
Matter. See Docket No. 58.
4. On August 3, 2017, the Lenders filed ... involuntary petition, Section 303(i)(2) provides
only that:
If the court dismisses a petition under this section other than on consent of all
petitioning creditors and the debtor
https://www.justice.gov/epstein/files/DataSet%209/EFTA00807038.pdf
EFTA01328713Set 10
2021-03-25354p57,648w
other governmental charges imposed with respect to the
Collateral (except to the
extent being contested in good faith and by appropriate proceedings which do not involve any
material risk ... Default Rate. Should there occur a Default, and if a voluntary or an
involuntary
petition under the United States Bankruptcy Code is filed by or against Grantor while such Default ... fact
that Secured Party has, prior to the filing of the voluntary or an involuntary petition under the United States
Bankruptcy
Code, acted in a manner which is inconsistent with
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01328713.pdf
EFTA01422410Set 10
2011-06-22369p87,774w
with the obligor of such Collateral Obligation and in the case
of an
involuntary petition, such petition has not been dismissed or stayed within
60 days of
filing; provided, however ... competent jurisdiction, the
enforceability of which order is
not subject to any pending contested matter or proceeding (as such terms are
defined in the
Federal Rules of Bankruptcy Procedure
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01422410.pdf
EFTA01097618Set 9
2007-09-0712p5,205w
days' opportunity to cure;
(iv) an involuntary proceeding shall be commenced or an involuntary
petition shall be filed seeking (a) liquidation, reorganization or other relief in
respect ... substantial part of its assets, and, in any such case, such proceeding or petition
shall continue undismissed for 60 days or an order or decree approving or
ordering ... entered;
(v) any DBZ Party shall (a) voluntarily commence any proceeding or file
any petition seeking liquidation, reorganization or other relief under any Federal,
state or foreign bankruptcy, insolvency, receivership
https://www.justice.gov/epstein/files/DataSet%209/EFTA01097618.pdf
under the Investment Company Act;
(f) an involuntary proceeding shall be commenced or an involuntary petition shall be
filed seeking (i) liquidation, reorganization or other relief in respect of either ... substantial part of
its assets, and, in any such case, such proceeding or petition shall continue undismissed for 60
days; or an order or decree approving or ordering ... Issuers (i) commences a voluntary proceeding (or consents to or
does not contest such a proceeding in a timely and appropriate matter) seeking (A) liquidation,
reorganization or other relief under
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01376205.pdf
EFTA01115421Set 9
2008-10-2062p23,790w
Exclusivity 4
SECTION 5.06. Notice 4
SECTION 5.07. Other Obligations 4
SECTION 5.08. Contest 4
SECTION 5.09. Condemnation/Casualty 4
SECTION 5.10. Default/Remedies 4
SECTION 5.11. Use of Property 4
SECTION ... Section 2.04 hcroof.
"Claims" means any and all administrative, regulatory or judicial actions, suits, petitions,
appeals, demands, demand letters, claims, liens, notices of noncompliance or violation,
investigations, proceedings, consent orders ... creditors, filed any voluntary petition in bankruptcy or suffered the filing of any
involuntary petition in bankruptcy by any of its aeditors, suffered the appointment of a receiver
to take
https://www.justice.gov/epstein/files/DataSet%209/EFTA01115421.pdf
EFTA00797688Set 9
2017-07-18177p83,195w
party thereto, whether
before or after the filing by or against Borrower of any petition for relief under the Bankruptcy
Code. As used herein, the term "Leases" shall not include ... days after
Borrower first receives written notice of such Lien or which is being contested in good faith in
accordance with the requirements of Section 4.3 and (v) such other ... pled guilty or no contest to, a felony, (2) has never been indicted or convicted of, or pled guilty
or no contest to, a Patriot Act Offense
https://www.justice.gov/epstein/files/DataSet%209/EFTA00797688.pdf
EFTA02707722Set 11
2002-12-3036p12,965w
same become due and payable, except to the extent the same are
being contested in good faith by appropriate proceedings in a diligent manner.
C. Existence and Compliance. Maintain ... liquidation and such
proceeding is not dismissed within sixty (60) days, the voluntary or involuntary
termination or dissolution of Borrower or Guarantor or the merger or consolidation of
Borrower ... assignment for the benefit of creditors by, or the filing of a
petition under bankruptcy, insolvency or debtor's relief law or the filing of a petition for
any adjustment
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02707722.pdf
EFTA01188913Set 9
2002-12-3036p12,966w
same become due and payable, except to the extent the same are
being contested in good faith by appropriate proceedings in a diligent manner.
C. Existence and Compliance. Maintain ... liquidation and such
proceeding is not dismissed within sixty (60) days, the voluntary or involuntary
termination or dissolution of Borrower or Guarantor or the merger or consolidation of
Borrower ... assignment for the benefit of creditors by, or the filing of a
petition under bankruptcy, insolvency or debtor's relief law or the fling of a petition for
any adjustment
https://www.justice.gov/epstein/files/DataSet%209/EFTA01188913.pdf
EFTA00095871Set 9
2019-07-1146p15,250w
TVPA criminalizes and attempts to
prevent slavery, involuntary servitude, and human trafficking for commercial gain." United
States v. Evans, 476 F.3d 1176, 1179 (11th Cir. 2007). Importantly, "the entire language ... contest the
jurisdiction of the United States District Court for the Southern District
of Florida over his person and/or the subject matter, and Epstein waives
his right to contest liability ... fees-and costs of contested litigation filed against him. Thus,
if after consideration of potential settlements, an attorney representative elects to file a
contested lawsuit pursuant to IS U.S.C
https://www.justice.gov/epstein/files/DataSet%209/EFTA00095871.pdf