
March Complete Victory in Western District of Oklahoma Bankruptcy Court Dismissal
Quinn Emanuel, working together with local Oklahoma counsel, recently obtained dismissal as bad faith filing of bankruptcy cases filed by the owners of two hospitals in rural Oklahoma, two months after the chapter 11 reorganization cases were filed.
The firm represents Rural Hospital Acquisition, First Physicians Realty Group, First Physicians Business Solutions, First Physician Resources, and First Physicians Services, the secured creditor, landlord, and companies providing management and related services to certain rural hospitals in Oklahoma.
In February , Quinn Emanuel filed a case in Oklahoma state court against the hospitals’ owners on behalf of the secured creditor and landlord, seeking money owed to our clients and the appointment of a receiver for the insolvent hospitals. Following a September in-person trial before the court in Caldwell, Oklahoma, the court granted our application for a receiver. On a Sunday evening in October , before the state court had entered the order that would formally appoint the receiver and set out the scope of his authority, and without any notice to the hospitals’ management company or vendors, the hospitals’ owners filed for bankruptcy. The filing created confusion and disruption for vendors and employees at the two hospitals, which had been operating smoothly for years and were filled to capacity during the COVID pandemic.
Knowing that courts rarely grant dismissal of chapter 11 cases in the early stages, Quinn Emanuel nonetheless filed within two weeks of the bankruptcy commencement a motion to dismiss, arguing that the cases were really a two party dispute and that the debtors were administratively insolvent, could not confirm a plan of reorganization, and had commenced the cases in bad faith to avoid the appointment of a receiver in the state court action. The U.S. Trustee joined in Quinn Emanuel’s motion. Quinn Emanuel swiftly sought discovery in support of its motion to dismiss via written discovery, as well as depositions of the debtors, two of their board members, and the principal of a management company—formed after Quinn Emanuel filed its motion to dismiss—with which the hospitals’ owners sought to replace our clients.
During the mid-December three-day remote trial on the motion to dismiss, Quinn Emanuel presented both fact and expert witnesses, deposition testimony, and cross-examined the witnesses who testified on behalf of the debtors. On December 30, , the court issued a page opinion granting Quinn Emanuel’s motion in full, finding that dismissal under Section of the Bankruptcy Code was warranted based on a continuing loss to the debtors’ estates and absence of a likelihood of rehabilitation, and on the debtors’ bad faith, and that dismissal was also warranted under Section of the Bankruptcy Code.
Federal Law: Districts by State
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Alabama (Middle, Northern, Southern) • Alaska • Arizona • Arkansas (Eastern and Western) • California (Central, Eastern, Northern, Southern) • Colorado • Connecticut • Delaware • Florida (Middle, Northern, Southern) • Georgia (Middle, Northern, Southern) • Hawaii • Idaho • Illinois (Central, Northern, Southern) • Indiana (Northern, Southern) • Iowa (Northern, Southern) • Kansas • Kentucky (Eastern, Western) • Louisiana (Eastern, Western, Middle) • Maine • Maryland • Massachusetts • Michigan (Eastern, Western) • Minnesota • Mississippi (Northern, Southern) • Missouri (Eastern, Western) • Montana • Nebraska • Nevada • New Hampshire • New Jersey • New Mexico • New York (Western, Eastern, Southern, Northern) • North Carolina (Western, Eastern, Middle) • North Dakota • Ohio (Southern, Northern) • Oklahoma (Eastern, Northern, Western) • Oregon • Pennsylvania (Eastern, Middle, Western) • Puerto Rico • Rhode Island • South Carolina • South Dakota • Tennessee (Eastern, Middle, Western) • Texas (Western, Eastern, Southern, Northern) • Utah • Vermont • Virginia (Western, Eastern) • Washington (Western, Eastern) • Washington, D.C. • West Virginia (Southern, Northern) • Wisconsin (Eastern, Western) • Wyoming

Alabama (Middle, Northern, Southern) • Alaska • Arizona • Arkansas (Eastern and Western) • California (Central, Eastern, Northern, Southern) • Colorado • Connecticut • Delaware • Florida (Middle, Northern, Southern) • Georgia (Middle, Northern, Southern) • Hawaii • Idaho • Illinois (Central, Northern, Southern) • Indiana (Northern, Southern) • Iowa (Northern, Southern) • Kansas • Kentucky (Eastern, Western) • Louisiana (Eastern, Western, Middle) • Maine • Maryland • Massachusetts • Michigan (Eastern, Western) • Minnesota • Mississippi (Northern, Southern) • Missouri (Eastern, Western) • Montana • Nebraska • Nevada • New Hampshire • New Jersey • New Mexico • New York (Western, Eastern, Southern, Northern) • North Carolina (Western, Eastern, Middle) • North Dakota • Ohio (Southern, Northern) • Oklahoma (Eastern, Northern, Western) • Oregon • Pennsylvania (Eastern, Middle, Western) • Puerto Rico • Rhode Island • South Carolina • South Dakota • Tennessee (Eastern, Middle, Western) • Texas (Western, Eastern, Southern, Northern) • Utah • Vermont • Virginia (Western, Eastern) • Washington (Western, Eastern) • Washington, D.C. • West Virginia (Southern, Northern) • Wisconsin (Eastern, Western) • Wyoming

Court bankruptcy western district
All events in this book are genuine, names and place names have been changed by the author or by the. Actors themselves for confidentiality purposes. It was a warm August late evening. I was driving my convertible and my hands were shaking slightly with excitement and anticipation of the coming stormy night. I knew for sure that it would be stormy.
Questions to Expect at the Bankruptcy Meeting of CreditorsOur naked bodies were beautifully reflected in the mirror. It seemed that I was watching us from the side. Again I remembered that couple from the park, I looked at the limp member. He was still carrying a condom filled with semen. I swallowed.
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He still continued to sleep, as if he did not feel at all what I was doing. I wanted more. I decided to take a chance. I slowly stepped into the bathroom, placing my right between his legs and squatting down.