Case 15-21233

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IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF CONNECTICUT
HARTFORD DIVISION
IN RE:
CURTIS JAMES JACKSON, III,
DEBTOR.

CHAPTER 11
CASE NO. 15-21233 (AMN)

DEBTORS MOTION FOR ORDER EXTENDING THE TIME TO FILE

HIS SCHEDULES OF ASSETS AND LIABILITIES AND
STATEMENT OF FINANCIAL AFFAIRS
Curtis James Jackson, III (the Debtor), the debtor and debtor in possession in the
above-captioned bankruptcy case (the Bankruptcy Case) under chapter 11 of title 11 of the
United States Code, 11 U.S.C. 101-1532, as amended (the Bankruptcy Code),1 files this
motion (the Motion) for an order extending the time for him to file his Schedules of Assets and
Liabilities (the SOAL) and Statement of Financial Affairs (the SOFA) and, in support, states
as follows:
I. Jurisdiction and Venue
1.

Petition Date and Creditors Meeting. The Debtor filed his voluntary petition for

relief under chapter 11 of the Bankruptcy Code on July 13, 2015 (the Petition Date), thereby
initiating this Bankruptcy Case. The creditors meeting under 341(a) is scheduled for August
7, 2015.
2.

Continued Operations. Under 301, the filing of the petition constituted an order

for relief under chapter 11 and, since that filing, under 1107 and 1108, the Debtor has
continued in possession and control of his assets and property and has continued to operate his
business and manage his affairs.

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All of the section references not otherwise defined herein will be to the Bankruptcy Code.

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3.

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Jurisdiction. This Court has jurisdiction to hear this matter under 28 U.S.C.

157 and 1334(b). This is a core proceeding under 28 U.S.C. 157(b)(2).

4.

Venue. Venue is proper before this Court in this district under 28 U.S.C. 1408

and 1409.
II. Factual Background
5.

The Debtor, Curtis James 50 Cent Jackson, III, is an internationally recognized

recording artist, an actor, an entrepreneur and a philanthropist. Since his entrance onto the music
scene in 2003 with his multi-platinum debut album, the Debtor has sold more than 22 million
albums worldwide, and has received numerous awards and Grammy nominations throughout his
career.
6.

As a result of the Debtors success, he has been fortunate to acquire a significant

amount of assets. Like many other celebrity entertainers that make their living in full view of the
public eye, however, the Debtor has accumulated a substantial amount of liabilities as well.
Notwithstanding this fact, the Debtors bankruptcy filing is not primarily a result of excessive
current expenses exceeding his current revenues, but rather the substantial costs of litigation and
resulting awards against him in the past year which total in excess of $20 million. While the
Debtor has substantial assets, he does not have the ability to pay the full amount of these
litigation claims and all other asserted claims at the present time, thereby necessitating this
chapter 11 filing.
7.

The Debtor filed his chapter 11 petition to obtain the full protections of the

bankruptcy laws in order to reorganize his financial affairs in a reasonable and timely manner
and in accordance with an approved plan for the benefit of his estate and all of his creditors. In

DEBTORS MOTION FOR ORDER EXTENDING THE TIME TO FILE HIS SCHEDULES OF ASSETS
AND LIABILITIES AND STATEMENT OF FINANCIAL AFFAIRS -- PAGE 2
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connection with this bankruptcy proceeding, the Court will determine the extent and value of the
Debtors assets and liabilities and, thus, Debtors net worth.
III. Relief Requested
8.

Under 521 and Rule 1007(c) of the Federal Rules of Bankruptcy Procedure (the

Bankruptcy Rules), the Debtor is required to file his SOAL and SOFA within 14 days of the
Petition Date. Because the Petition Date was July 13, 2015, the current deadline for the Debtor
to file his SOAL and SOFA is July 27, 2015.
9.

By this Motion, the Debtor requests that this Court, for the reasons set forth

below, extend the 14-period to file his SOAL and SOFA for an additional 7 days until August 3,
2015, without prejudice to the Debtors ability to request additional time should it become
necessary.
IV. Cause Exists For an Extension of Time
to File the SOAL and SOFA
10.

The Debtors business operations are run through numerous corporate entities that

he has an interest in (collectively, the Related Entities), and that include the following:
ENTITY

OPERATIONS OF THE RELATED ENTITY

Curtis James Jackson, III

Financial advisory and accounting services

Cheetah Vision Inc.

Television shows and movies

Tomorrow, Today Entertainment Inc.

Website (thisis50.com)

G-Unit Film and Television Inc.

Film company

G-Unit Touring Inc.

Touring company

G-Unit Brands Inc.

Endorsement deals

DEBTORS MOTION FOR ORDER EXTENDING THE TIME TO FILE HIS SCHEDULES OF ASSETS
AND LIABILITIES AND STATEMENT OF FINANCIAL AFFAIRS -- PAGE 3
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ENTITY

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OPERATIONS OF THE RELATED ENTITY

Rotten Apple Records Inc.

Royalties, side artists, publishing

50s Liquid Assets Inc.

Royalties

G-Unit Merchandising Inc.

FEA deal tour only

G-Unit Books Inc.

Book deals, royalties

G-Unit Adult Films Inc.

Production of adult films, royalties

G-Unit Records Inc.

Label, office, salaries

G-Unity Foundation Inc.

Charity

Hollow Point Inc.

Corporate entity not presently used

Love Me Love Me Not Short Film LLC

Short film, royalties

Things Fall Apart LLC

Short film, royalties

In the Passing Lane LLC

Ownership of automobiles, payment of drivers, all carrelated expenses

Before I Self Destruct Short Film LLC

Short film, royalties

G-Unit Clothing LLC

Inactive corporate entity, but possible new clothing deal

in the works

50 Cent Music LLC

Inactive corporate entity

CT Lights LLC

Connecticut home expenses and mortgage, Los Angeles

rental property

SMS Promotions, LLC

Promotion of boxers, and the operations of a Las Vegas,

Nevada gym

Animal Ambition Short Film LLC

Inactive corporate entity

Street King LLC

The Debtor made an investment in this entity through

50s Liquid Assets Inc.

TMT Promotion LLC

Inactive corporate entity that previously handled boxing

promotion for Floyd Mayweather

DEBTORS MOTION FOR ORDER EXTENDING THE TIME TO FILE HIS SCHEDULES OF ASSETS
AND LIABILITIES AND STATEMENT OF FINANCIAL AFFAIRS -- PAGE 4
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ENTITY

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OPERATIONS OF THE RELATED ENTITY

Tomorrow, Today Short Film LLC

Inactive corporate entity

Sire Spirits LLC

Effen Vodka / Beam deal

Broadway Boxing LLC

Inactive corporate entity that is slated to be involved

with boxing promotions in the future

CJJ Enterprises LLC

Inactive corporate entity

SMS Audio LLC

Headphones

SMS Kono Audio LLC

Headphones

G Note Records, Inc.

Recording deals

11.

Due to the number of the Related Entities, the complexity of the Debtors books

and records, and the potential volume of materials to be included in his SOAL and SOFA, the
Debtor will be unable to complete his SOAL and SOFA within the 14 days mandated under
Bankruptcy Rule 1007(c), and he requires an additional seven (7) days, or until August 3, 2015.
12.

The Debtor submits that this Motion is being filed in good faith and will not

prejudice the rights of any creditors or parties in interest.

13.

No previous request for the relief sought herein has been made to this or any other

court.
V. Prayer
The Debtor prays that this Court grant this Motion by issuing an order that extends the
deadline for the Debtor to file his SOAL and SOFA an additional 7 days, until August 3, 2015,
and awards the Debtor such other and further relief, special or general, at law or in equity, as this
Court may deem just and proper.

DEBTORS MOTION FOR ORDER EXTENDING THE TIME TO FILE HIS SCHEDULES OF ASSETS
AND LIABILITIES AND STATEMENT OF FINANCIAL AFFAIRS -- PAGE 5
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Dated: July 21, 2015

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Respectfully submitted,
NELIGAN FOLEY LLP
/s/ Patrick J. Neligan, Jr.
Patrick J. Neligan, Jr.
Texas State Bar No. 14866000
pneligan@neliganlaw.com
James P. Muenker
Texas State Bar No. 24002659
jmuenker@neliganlaw.com
325 N. St. Paul, Suite 3600
Dallas, Texas 75201
Telephone: (214) 840-5300
Facsimile: (214) 840-5301
ZEISLER & ZEISLER P.C.
/s/ James Berman
James Berman
CT Bar No. 06027
jberman@zeislerlaw.com
10 Middle Street, 15th Floor
Bridgeport, Connecticut 06604
Telephone: (203) 368-4234
Facsimile: (203) 367-9678
PROPOSED COUNSEL TO THE DEBTOR

Certificate of Service
The undersigned counsel hereby certifies that the 21th day of July, 2015, a true and
correct copy of the foregoing was via first class mail upon the persons named on the attached
Service List and electronically via this Courts ECF notification system.
/s/ Patrick J. Neligan, Jr.
Patrick J. Neligan, Jr.

DEBTORS MOTION FOR ORDER EXTENDING THE TIME TO FILE HIS SCHEDULES OF ASSETS
AND LIABILITIES AND STATEMENT OF FINANCIAL AFFAIRS -- PAGE 6
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MASTER SERVICE LIST

Curtis James Jackson, III
PROPOSED DEBTORS COUNSEL
Patrick J. Neligan, Jr.
James P. Muenker
Neligan Foley LLP
325 N. St. Paul, Suite 3600
Dallas, TX 75201

James Berman
Zeisler & Zeisler P.C.
10 Middle Street, 15th Floor
Bidgeport, CT 06604

DEBTOR
Curtis James Jackson, III
c/o Nikki Martin
G-Unit Records, Inc.
264 West 40th Street, 15th Floor
New York, NY 10018
U.S. TRUSTEE
Office of the United States Trustee
Attn: Kim McCabe
Giaimo Federal Building
150 Court Street, Room 302
New Haven, CT 06510
GOVERNMENT AGENCIES
Internal Revenue Service
P.O. Box 7346
Philadelphia, PA 19101-7346

Securities and Exchange Commission

100 F Street, NE
Washington, DC 20549

Internal Revenue Service

Centralized Insolvency Operation
P.O. Box 21126
Philadelphia, PA 19114-0326
SECURED CREDITOR
Suntrust Mortgage
P.O. Box 79041
Baltimore, MD 21279
20 LARGEST UNSECURED CREDITORS
Sleek Audio, LLC, Mark Krywko,
Michael Krywko, Jason Krywko and
Gregory WSysocki
3904 9th Avenue West
Bradenton, FL 34205

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Lastonia Leviston
c/o Darren M. Gelber
Wilentz, Goldman & Spitzer
110 William Street, 26th Floor
New York, NY 10038

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Suntrust Bank
P.O. Box 79079
Baltimore, MD 21279

Reed Smith
1901 Avenue of the Stars, Suite 700
Los Angeles, CA 90067

Robins Kaplan LLP

800 LaSalle Avenue
Minneapolis, MN 55402

Garvey Schubert Barer

100 Wall Street, 20th Floor
New York, NY 10005

Bentley Financial Services

75 Remittance Drive, Suite 738
Chicago, IL 60675

American Express
P.O. Box 1270
Newark, NJ 07101-1270

G. Collins & Company LLC

1410 Broadway, Suite 1905
New York, NY 10018

Premium Assignment Corp.

P.O. Box 800
Tallahassee, FL 32314

Dorothy McJesus
c/o Michael Malkovich
Xanthakos & Malkovich
43 Center Street, Suite 101
Northampton, MA 01060

Candance Scott
c/o Michael Malkovich
Xanthakos & Malkovich
43 Center Street, Suite 101
Northampton, MA 01060

539 38th Street, LLC

P.O. Box 685
Hackensack, NJ 07602

Stephen J. Savva P.C.

546 Fifth Avenue, 6th Floor
New York, NY 10036

Eversource
P.O. Box 650032
Dallas, TX 75265-0032

Erin McSherry
295 Park Avenue S #2G
New York, NY 10010

Moritt Hock & Hamroff

400 Garden City Plaza
Garden City, NY 11530

Feldman and Hickey LLC

Waterside Office Park
10 Waterside Drive, Suite 303
Farmington, CT 06032

Curtis J. Jackson, Sr.

6 West Circle Drive
Valley Stream, NY 11581-1517

8X10 Boutique LLC

2700 N. Miami Avenue, #1001
Miami, FL 33127

PARTIES REQUESTING NOTICE

Elizabeth J. Austin
Pullman & Comley, LLC
850 Main Street
Bridgeport, CT 06604

Jessica Grossarth
Pullman & Comley, LLC
850 Main Street
Bridgeport, CT 06604

Michael R. Enright
Robinson & Cole
280 Trumbull Street
Hartford, CT 06103

Patrick M. Birney
Robinson & Cole
280 Trumbull Street
Hartford, CT 06103

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