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1. Case 09-33918-hdh11 Doc 780 Filed 02/17/12 Entered 02/17/12 09:32:50 Desc
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ERIC A. LIEPINS
ERIC A. LIEPINS, P.C.
12770 Coit Road
Suite 1100
Dallas, Texas 75252
(972) 991-5591
(972) 991-5788 - telecopier
ATTORNEY FOR HULSE STUCKI
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
IN RE: §
§
FIRSTPLUS FINANCIAL GROUP, INC § CASE NO. 09-33918-HDH-11
§
DEBTOR. §
APPELLANT’S DESIGNATION AND STATEMENT OF ISSUES ON APPEAL
Hulse Stucki, Creditor, party-in-interest and Appellant in the above styled and numbered
bankruptcy proceeding and in connection with the appeal of the Court’s Order Confirming Trustee’s
Amended plan of Liquidation for the Debtor [Docket #770] entered on February 7, 2012, filed this
its designation of Items for the record and Statement of Issues on Appeal made pursuant to and in
compliance with the Federal Rules of Bankruptcy procedure 8006.
DESIGNATION OF THE RECORD
Appellant designates the following items to be included in he record on appeal:
Number Item Docket Number
1. Motion Pursuant to section 502(a) of the Bankruptcy
2. Case 09-33918-hdh11 Doc 780 Filed 02/17/12 Entered 02/17/12 09:32:50 Desc
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Code to allow Claim for Breach of Contract and Rule
9019 of the Federal Rules of Bankruptcy Procedure
to approve Settlement and Compromise 515
2. Trustee’s First Amended Plan of Liquidation
for Debtor 601
3. Disclosure statement for Chapter 11 Trustee’s
Amended Plan of Liquidation for Debtor 603
4. Order Confirming Plan 770
Pursuant to Local Rule 8006.2 copies of the materials identified above will be provided to
the clerk of the Bankruptcy Court on or before 20 days from the date of the filing of this Designation.
STATEMENT OF ISSUES ON APPEAL
1. Whether the Bankruptcy Court erred in finding that the claims of former shareholders
of the Debtor were not subject to mandatory subordination pursuant to 11 U.S.C.
§510(b).
2. Whether the Bankruptcy Court erred in finding that the treatment of former
shareholder claims pari passu with the claims of allowed general unsecured creditors
did not violate the absolute priority rule.
Respectfully submitted,
3. Case 09-33918-hdh11 Doc 780 Filed 02/17/12 Entered 02/17/12 09:32:50 Desc
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_/s/ Eric Liepins____________
Eric A. Liepins, SBN 12338110
12770 Coit Road
Suite 1100
Dallas, Texas 75251
(972) 991-5591
(972) 991-5788 - telecopier
ATTORNEY FOR HULSE STUCKI
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Notice of Designation was sent
to Peter Franklin, 10501 N. Central Expressway, Suite 106, Dallas, Texas 75231 on this the 17th day
of February 2012.
_____/s/ Eric Liepins__________________
Eric A. Liepins