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Windsor Terrace Healthcare, LLC
1:23-bk-11200
Bankr. C.D. Cal.
Aug 20, 2024
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Background

  • Debtors filed a Fourth Omnibus Motion to disallow or reclassify various creditors' claims in their Chapter 11 case.
  • A stipulation between Debtors and McKesson Medical-Surgical, Inc. resolved the objection to McKesson’s claims; court order entered approving this.
  • Court granted the motion to disallow or reclassify claims against several specific creditors, but continued a hearing on Recovery Nursing Agency’s disputed priority claim.
  • Fabienne Ouapou-Lena’s claim, originally classified as priority under 11 U.S.C. § 507(a)(4) and (a)(5), was challenged for not meeting statutory requirements.
  • Court determined Ms. Ouapou-Lena’s employment ended more than 180 days before bankruptcy filing, rendering her claim nonpriority.
  • Debtors must serve reclassified claimants with plan ballots so they may elect treatment under Class 4; amount of Ouapou-Lena’s claim to be revisited later.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether McKesson’s claim was improperly classified Debtors: Claim should be reclassified/disallowed McKesson: Objection resolved via stipulation Denied as moot due to stipulation
Priority status of Ms. Ouapou-Lena’s wage/benefit claims Ouapou-Lena: Claims should be priority (timing/met criteria) Debtors: Employment ended >180 days before bankruptcy; does not qualify Claims reclassified as unsecured nonpriority
Whether continued hearing is necessary for Recovery Nursing Agency’s disputed priority claim Debtors: Disallow/reclassify claim immediately Recovery Nursing: Dispute priority status Hearing continued to later date
Challenge to amount of Ms. Ouapou-Lena’s claim Debtors raise additional issues on amount Ouapou-Lena not given opportunity to respond yet Court reserves ruling on amount challenge

Key Cases Cited

  • Lundell v. Anchor Const. Specialists, Inc., 223 F.3d 1035 (9th Cir. 2000) (establishes burden-shifting framework for evaluating objections to proofs of claim)
  • In re Laptops Etc. Corp., 164 B.R. 506 (Bankr. D. Md. 1993) (clarifies claimant’s burden of persuasion after objection supported by probative evidence)
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Case Details

Case Name: Windsor Terrace Healthcare, LLC
Court Name: United States Bankruptcy Court, C.D. California
Date Published: Aug 20, 2024
Docket Number: 1:23-bk-11200
Court Abbreviation: Bankr. C.D. Cal.