San Francisco Bankruptcy Lawyer Blog

John Lauderdale, from Carmel, CA, has credits for being the stage manager for Jeopardy, Wheel of Fortune, and American Gladiators. It is amazing how some shows and people have staying power while celebrities once on top have unexpectedly divorced and left in financial ruin.

Jon Gosselin, former star of "Jon & Kate Plus 8" faced severe financial difficulties with an unsold home and mounting debts in 2009 after earning more than $2 million with Kate from their TV show. With the divorce, Kate still got gigs with her own show and on Dancing with the Stars. According to www.californiafamilylawblog.com, Jon, with $13,000 per month in child support and $90,000 to family law attorneys, was looking at the possibility of a Chapter 13 bankruptcy filing.

Prior to his death, Gary Coleman blamed his financial woes on mismanaged finances and a lifelong medical condition.

Kevin Coster and Cindy Silva's divorce cost an estimated $80 million.

After eight years of dating, Harrison Ford and Calista Flockhart got married in June 2010 in New Mexico, where Ford is filming "Cowboys and Aliens." Harrison Ford's 2004 divorce from Melissa Mathison cost an estimated $85 million.

Marion Jones won five medals at the Olympics in 2000 and signed multimillion-dollar endorsement afterwards, but after allegations of steroid use, she spent a significant amount of money on legal representation to fight the allegations. The legal distractions cost her major international meets. When Jones became deep in debt, and $2.5 million mansion went through mortgage foreclosure.

Mike Tyson filed bankruptcy in 2003 after spending on cars, mansions, and a defense for rape.

Donald Trump filed for Chapter 11 protection in 2004 and 2009 to reorganize debts related to construction.

Olympic Gold Medal ice skater Dorothy Hamill came into difficult times and made a choice to file for bankruptcy in 1996.

Continue reading "Celebrity Bankruptcies" »

When determining whether to file bankruptcy, it helps to have background on bankruptcy terms:

AUTOMATIC STAY: injunction that automatically stops lawsuits, foreclosure, garnishments, and collection activity against the debtor the moment a bankruptcy petition is filed.

BANKRUPTCY: legal procedure for dealing with debt.

BANKRUPTCY CODE: Title 11 of the United States Code (11 U.S.C. §§ 101- 1330), the federal bankruptcy law.

BANKRUPTCY ESTATE: legal or equitable interests of the debtor in property at the time of the bankruptcy filing. The estate includes all property in which the debtor ownership even when property is used by another.

BANKRUPTCY JUDGE: judicial officer who is the court official with decision-making power over federal bankruptcy cases.

BANKRUPTCY PETITION: formal request for the protection of federal bankruptcy laws.

BANKRUPTCY TRUSTEE: private individual or corporation appointed in Chapter 7, Chapter 12, and Chapter 13 cases to represent the interests of the bankruptcy estate and the debtor's creditors.

CHAPTER 12: bankruptcy designed for family farmers or family fishermen with regular annual income to propose and carry out a plan to repay debts.

CHAPTER 7: chapter of the Bankruptcy Code providing for "liquidation," i.e., the sale of a debtor's nonexempt property and the distribution of the proceeds to creditors.

CHAPTER 11: reorganization bankruptcy, usually involving a corporation or partnership. A Chapter 11 debtor usually proposes a plan of reorganization to keep its business alive and pay creditors over time.

CHAPTER 13: chapter of the Bankruptcy Code providing for adjustment of debts of an individual with regular income. Chapter 13 allows a debtor to keep property and pay debts in 3-5 years.

REAFFIRMATION AGREEMENT: agreement by Chapter 7 debtor to continue paying a dischargeable debt after the bankruptcy, usually for the purpose of keeping collateral or mortgaged property subject to repossession.

Continue reading "Glossary of Bankruptcy Terms - San Francisco" »

There are two US Bankruptcy judges in San Francisco. The US Bankruptcy court in San Francisco is located at 235 Pine Street, San Francisco, CA, in the heart of the financial district. The judges' names are Judge Dennis Montali and Judge Thomas Carlson.

According to his bio on the US Bankruptcy Court, Northern District of California web site, Judge Carlson graduated from Beloit College, B.A. in 1969, and then went on to Brandeis University, for graduate studies in American History from 1970-71. He graduated from Harvard Law School, J.D. in 1975 and received a LLM in Tax from N.Y.U. Law School, LL.M. in 1985. Judge Carlson is well respected by attorneys for seeing things in cases that sometimes the parties do not catch. He appears to want the best interests of all parties served, even continuing status conferences sometimes to give parties another chance to review their issues to make sure they are making the right decisions. In one recent status conference in June 2010, he asked the debtor to review again to see if dismissal of his Chapter 11 case rather than converting to Chapter 7 was really in his best interest, considering he had unsecured debt that could be discharged in a Chapter 7.

According to his bio on the US Bankruptcy Court, Northern District of California web site, Judge Montali received a Bachelor of Arts, University of Notre Dame in June 1961, and a Juris Doctor, University of California, Berkeley in June 1968. He was appointed United States Bankruptcy Judge Northern District of California, San Francisco Division in April 23, 1993, and reappointed in April 23, 2007.

A bankruptcy judge is not the same as a state court judge. The bankruptcy code is federal law and the US Bankruptcy Court has exclusive jurisdiction in all bankruptcy cases. A person cannot file bankruptcy in a state court. Bankruptcy judges are federal judges. The bankruptcy court is a court of specific jurisdiction, meaning that a person cannot file any other claim in bankruptcy court except for matters related to bankruptcy. If there is a related civil action, like a contract dispute, the person must file the action in a state court.

A debtor might need to appear in bankruptcy court for status conferences or motions when there are decisions to make on keeping personal property that the person does not own outright, disputing reliefs from automatic stays, or asking to re-assume liability for a certain debt.

Continue reading "US Bankruptcy Judges in San Francisco" »

When observing a US Bankruptcy Court status conference in San Francisco, there is often an appearance made by the US Trustee and the Panel Trustee. These individuals have different roles in a bankruptcy case.

The US Trustee works for the Department of Justice responsible for overseeing the administration of bankruptcy cases and private Panel Trustees, and ensuring compliance with the Bankruptcy Code. The US Trustee ensures that the public interest is being served by the proper administration of all bankruptcy cases. The US Trustee appoints the Panel Trustees that filers meet about five weeks after filing at 341 creditors' hearings.

If the Panel trustee notices fraud or the ability for a debtor to pay a fraction of debts over a 60 month period then it's reported to the US Trustee where they will litigate and attempt to dismiss the debtor. US Trustee administration ensures debtors are paying their fees and submitting all required schedules. The US Trustee gets its fees in certain bankruptcy cases like Chapter 11 cases by calculating a percentage from the operating reports that debtors turn in each quarter. Operating reports are also important for keeping parties informed on the cash flow for secured creditors. The rents generated by properties securing debt are also security for secured creditors.
Payments made each quarter to US Trustee are based on cash flow in operating reports. Reports are filed under penalty of perjury.

The Panel Trustee works for creditors even though paid by the debtor. When a debtor files bankruptcy without a Panel Trustee appointed, the debtor is said to be a debtor-in-possession. The debtor no longer a debtor-in-possession after a Panel Trustee is appointed. The Panel Trustee might engage attorneys and accountants to find out how the funds in the estate were used, but usually would try to preserve estate assets by not conducting investigations that are not beneficial to creditors. For instance, forensic accounting, because of the expense amounting to as much as $50,000, is saved for situations where there are fraud or preference payments.

Continue reading "Panel Trustee and US Trustee at San Francisco Bankruptcy Status Conferences" »

For someone interested in learning about bankruptcy laws, the hearings in San Francisco in front of Judge Thomas Carlson might be more instructive than reading a book. Anyone can go to the 23rd Floor at 9:30 am and sit in the audience to listen in on the bankruptcy hearings. For example, on June 28, 2010, there was an interesting case about a debtor deciding whether to convert to Chapter 7 or dismiss the case.

In a dismissal, the debtor goes back to where he was as if he never filed for bankruptcy. Once the case is dismissed, the debtor no long has the protection of the automatic stay, allowing the creditors can go after him again for all the amounts owing. There is no discharge of any debts. The debtor continues to owe all debt as if never filed bankruptcy.

If a debtor converts to Chapter 7, he will have the advantage of a discharge as long as no one objects. A discharge is a federal court order that all creditors can no longer go after the debtor. The Panel Trustee sells off the assets in the estate and uses the proceeds to pay off as much of the debt as possible. If the bankruptcy estate does not have any assets to pay off the debts, the debts that cannot be paid are discharged. There is a priority to the payment of the debts. The Panel Trustee, and his attorneys and accountants, for example, get paid first. Unsecured debts like loans from family members get paid off last.

Besides discharge, another advantage of Chapter 7 over dismissal is that the debtor does not need to contribute any funds into the payment of debts. For instance, if the Panel Trustee's fees exceeded the assets available in the bankruptcy estate, the Panel Trustee is stuck with whatever amount he is able to get from the sale of assets. In a discharge, the Panel Trustee would be entitled to his full fees.

If the Panel Trustee does not want to use property for the payment of the debts like when the Panel Trustee might incur liabilities in managing property or the property is secured with loans that are over the value of the funds generated from the property, the Panel Trustee might abandon the property. When property is abandoned, it goes back to the debtor. If it was real property, the debtor can allow foreclosure if he does not want it anymore, or if he wants to save the property, he can cure amounts owed, pay off amounts due and payable, and then maintain payments.

If the debtor does not want the Panel Trustee to sell off a specific asset such as cars he wants to keep, he can buy back the property. For example, with cars, he can pay the Panel Trustee the Kelly Blue Book value.

Continue reading "US Bankruptcy Court Hearings in San Francisco" »

With companies collapsing the economic downturn, investors should be aware of insider trading laws and how bankruptcies affect the companies they invest in. Rule 16(b) of the Securities Exchange Act of 1934 provides that directors, officers and ten-percent shareholders shall not buy and sell stocks or sell and buy stocks within a six-month period. Any profits acquired in violation of Rule 16(b) must be returned to the company. The profit is calculated by matching the highest sales price against the lowest purchase price for any six-month period. The profit can be either an avoided loss or a gain.

An officer and director of a company owe a duty of loyalty to the corporation and is required to put the company's interests ahead of his own at all times. Thus, if they are involved in any short-swing profits, they must return the money to the company.

When a company files bankruptcy, the officers and directors must perform in good faith and act in a manner the officer believes is in the best interest of the corporation, exercising that degree of care an ordinary person exercises under similar circumstances. Under the business judgment rule, officers and directors are insulated from liability for decisions that turn out poor or erroneous, when they act in good faith, exercise due care, and have a rational basis when making decisions.

Most publicly-held companies will file under Chapter 11 so management can still run the business and control the bankruptcy process. If the company still trades on a stock exchange, the company must continue to file SEC reports informing significant developments.

During bankruptcy, bondholders will stop receiving interest and principal payments, and stockholders will stop receiving dividends. A bondholder may receive new stock, new bonds, or combination of stock and bonds in exchange for bonds. For a stockholder, the trustee may ask a shareholder to send back the certificates for the old stock in exchange for new shares in the reorganized company. The new shares may be fewer in number and may be worth less than old shares. The reorganization plan spells the rights for an investor.

If the company's liabilities are greater than its assets, an investor's stock may be worthless.

Rinne Legal provides counseling to individuals, families and small businesses in financial difficulties. Call for a no charge initial consultation.

Every investor should understand Rule 10b-5 of the Securities Exchange Act of 1934 makes it unlawful for any person directly or indirectly, (1) by use of any means of interstate commerce (2) to make a material omission or misrepresentation of material fact, (3) with scienter, (4) in connection with the purchase or sale of any security.

Means of interstate commerce include transactions involving a publicly traded company listed on a national exchange, and use of the telephone. A fact is material, if a reasonable investor would consider it in making an investment decision. Scienter involves the intent to deceive.

Sometimes, there may be a Rule 10b-5 violation if a company knew that it might suffer a shortfall in its revenue but while in its earnings announcement it omits this information. A decline in its revenue, leading to inability to pay creditors, may not just be a Rule 10b-5 violation, but a bankruptcy concern.

If the company comes out of bankruptcy, investors should be aware there may be different types of common stock, with different ticker symbols, trading for the same company. One common stock is the stock on the market when the company went into bankruptcy, and the second is the common stock that the company issued as part of its reorganization plan.

The investor should be sure to understand which shares the investor purchases. The shares issued before the company filed for bankruptcy may be worthless if the company emerges from bankruptcy and has issued new common stock.

A person commits insider trading when he trades on material nonpublic information, or omits material nonpublic information in the course of dealing in securities. Persons with insider information are required by Rule 10b-5 to abstain from trading or to disclose the information. A duty to disclose applies to persons who have a fiduciary relationship with the stock issuer like directors and officers.

Rinne Legal provides counseling to individuals, families and small businesses in financial difficulties. Call for a no charge initial consultation.

In order to prove a prima facie case for common law defamation, a plaintiff must show (1) defamatory statement of fact, (2) of or concerning the plaintiff, (3) publication by defendant to a third person, (4) damages to plaintiff's reputation, and (5) no defenses by defendant.

The U.S. Bankruptcy Court for the Southern District of Texas found in a Chapter 11 proceeding in In re William Perry that emailing hyperlinks directing others to view a third-party's blog is a sufficient publication for defamation under Texas law.

Perry and David Wallace were in a business relationship where a partnership dissolved. The court focused on Wallace filed defamation claims against Perry, the debtor, about an email that Perry sent to people containing hyperlinks to the Rhymes with Right blog, which Perry did not write, but contained a discussion of Wallace's associations with the son of former British Prime Minister Margaret Thatcher. The court found the statements falsely "insinuated ... that Wallace was an arms dealer and was in league with Mark Thatcher in attempting to overthrow the government of Equatorial Guinea."

The court ruled that Perry's email containing hyperlinks to the blog met the publication element of Wallace's defamation allegation under Texas law: "a statement is published when it is said orally, put into writing or in print, and the statement was published in such a way that the third parties are capable of understanding its defamatory nature."

In Texas, "an email, just like a letter or a note, is a means for a statement to be published so that third parties are capable of understanding the defamatory nature of the statements." The court held Perry acted with actual malice and defamed Wallace by sending the links with other defamatory statements.

The decision goes to show that people have to be careful of their online communications whether by email or on the Internet.

Rinne Legal provides counseling to individuals, families and small businesses in financial difficulties. Call for a no charge initial consultation.

When involved in litigation or bankruptcy filings, everyone needs to be aware of the public nature of the court system. Unless there is a reasonable expectation of privacy, people cannot expect what they are doing to be protected as confidential even though they involve personal matters.

A couple in Pennsylvania, Aaron and Christine Boring, sued in federal appeals court about having a photo of their home included on Google "Street View" based on trespass. The three-judge panel agreed the photos depicted nothing that invaded the couple's privacy.

Google launched Street View around 2007 by going around the country with cars strapped with cameras that took 360-degree views at the street level of cities. The pages permit visitors to take virtual tours through neighborhoods on their computers. Many real estate companies started to use the photos to market homes since the launch. The argument that there is no invasion of privacy is that the images are out in the public. Anyone walking by a person's home would see exactly what is on Street View. Google has taken some privacy measures by blocking out license plates on cars and offers a feature for people to remove an image such as a home or car if they do not want the image on the Internet.

Aaron and Christine Boring lived on a private street. They sued Google for invasion of privacy and trespass, alleging the photos were taken without permission from their driveway that had postings with "Private Road" and "No Trespassing".

The U.S. Third Circuit Court of Appeals agreed with the district court as to the privacy claim because the photos were not offensive. The appeals court reversed the district court on the trespass claim: "Here, the Borings have alleged that Google entered upon their property without permission. If proven, that is a trespass, pure and simple. There is no requirement in Pennsylvania law that damages be pled, either nominal or consequential." The district court rejected the claim because the Borings did not plead damages.

The appellate court denied the couple's request for an injunction to order Google to remove the pictures from its site because Google had "long since" taken down the photos.

Rinne Legal provides counseling to individuals, families and small businesses in financial difficulties. Call for a no charge initial consultation.

The Commissary Operations case (Case No. 308-06279) was handed down a decision on January 6, 2010. The United States Bankruptcy Court for the Middle District of Tennessee helped creditors defending against preference actions.

Section 503(b)(9) of the Bankruptcy Code gives first priority administrative status to claims for goods received by the debtor within 20 days of the bankruptcy filing. The Section was part of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 to provide additional protection to trade creditors by allowing suppliers of goods to assert an administrative expense claim for the value of goods sold and delivered to, and received by, a customer in the ordinary course of business within 20 days of the customer's bankruptcy filing.

In the Commissary Operations case, Bankruptcy Judge Marian F. Harrison ruled that the goods that make up the 20-day claims may also be included in the subsequent new value defense under Section 547(c)(4) of the Bankruptcy Code. The subsequent new value defense allows preference defendants to reduce their preference liability if they supplied the debtor with new products or services after the payments sought to be recovered were received. The defense applies when the debtor and the creditor have a running relationship.

In the Commissary Operations case, the debtor wanted to disqualify 20-day claims from being counted as new value. The court decided that result would deprive creditors of the priority given to them under the Bankruptcy Code.

Judge Marian F. Harrison said requiring creditors to choose between a 20-day claim and preserving their right to assert a new value defense that includes deliveries made to the debtor within the 20-days before to the bankruptcy filing would chill their willingness to do business with troubled entities.

Continue reading "Bankruptcy Code Section 503(B)(9) Claims" »

Much of reaching financial security in order to enjoy life is like getting the bike mojo back to enjoy the ride. As in bicycle riding, where safety requires having the right gear, understanding traffic laws, and keeping a bike well maintained, credit counseling 101 teaches about informal debt repayment plans, bankruptcy filing laws, and calculating income status.

On gear, bicyclists are advised to always wear a helmet. When in an accident, helmets are sick, head injuries are not. With a debtor, counseling offers a proposal to settle with creditors. According to Nolo Press in "The New Bankruptcy, Will it Work For You?", if a credit counseling agency proposes a settlement that repays at least 60% of a debtor's debts, and the creditor does not accept the plan, the credit may be penalized by only being able to collect up to 80% of the total claim, when and if a debtor's property gets distributed in bankruptcy.

Aside from helmets, the most purchased safety equipment in cycling is probably the glove. Gloves protect the skin on the palms of hands when there is an accident on pavement. With credit counseling, the second value that people get is training on how to calculate income status. In 2005, the bankruptcy laws change to require higher income individuals with mostly consumer debts to file Chapter 13. In deciding to file bankruptcy, use the average gross income received during the 6 months prior to the month a debtor desires to file. This number is the current monthly income.

In bicycling, cyclists in competition prevent lost of self respect by using mouth guards. Mouth guards prevent blows to the chin from messing the teeth if there is an accident just like a boxer who makes sure his pearly whites are well protected in a fight. A debtor should not let the word "bankruptcy" get him down. Credit counseling will reveal that "buy, buy, buy" has been the seductive message in the United States. Bankruptcy is based on forgiveness, not redemption.

Cycling safety involves knowing traffic laws in order to survive a bike accident in difficult traffic situations. Knowing bankruptcy laws allows debtors not to succumb to discrimination in challenging financial situations. For instance, an employer may not terminate a worker because of a bankruptcy filing. Bankruptcy is not to work against someone who needs security clearance such as for a job with the CIA or FBI. Government agencies may not discriminate someone for a license, public benefits, or housing because of a bankruptcy filing.

Continue reading "Financial Safety" »

The Securities Investor Protection Corporation (SIPC) is known as the first line of defense when a brokerage firm fails, owing customers cash and securities that are missing from customer accounts. The SIPC either acts as trustee or works with an independent court-appointed trustee in a missing asset case to recover funds. In the Madoff case, the SIPC-appointed trustee is Irving Picard.

U.S. Bankruptcy Judge Burton Lifland ruled in March 2010 on the process for determining how much money investors may get to receive from the SIPC on the Madoff Ponzi scheme. The judge agreed with Irving Picard that investors could claim only the amount they first invested with Madoff (minus withdrawals).

After a full briefing by Trustee Irving Picard, the SIPC, the Securities and Exchange Commission (SEC), and customer claimants, supporting and opposing to Picard's motion on the proper interpretation of "net equity" under the Securities Investor Protection Act, and after a hearing, the Burton R. Lifland issued an opinion on March 1, 2010 approving Picard's "net investment" method of determining customer claims.

Continue reading "Madoff Investors" »

On March 9, 2010, the San Francisco Chronicle reported "Lindsay Lohan suing for $100 million over E-Trade 'milkaholic' baby ad". The ad allegedly parodied Lohan's life for profit.

The right of publicity allows an individual to sue when the person's name, likeness, or other personal attributes are used without permission for a commercial purpose, such as advertising or to sell a product. Identity may involve any manner that evokes identity not necessarily a use of a person's name. California, Civil Code Section 3344 provides statutory damages, punitive damages, and attorneys fees and costs, among other remedies.

Injuries from the violations of the right of publicity are not simple to evaluate like injuries from a car accident. Usually the claims are for emotional distress, which are about as difficult to prove as soft tissue injuries. Soft tissue injuries are difficult to prove because they are not permanent. With soft tissue injuries, there is discomfort to the muscles or nerves, but a person cannot pinpoint them like broken bones or hard injuries that cause life disruptions.

In a lawsuit for violation of publicity rights, the injured party may need to go through mental exams or therapy like in an accident. Medical bills will be used to evaluate the seriousness of an injury. Diagnosis of the injury may run up the medical bills with tests and exams, but bills relating to treatment determine the seriousness. Medical bills from doctors, hospitals, clinics are given more weight than therapy and chiropractors. Therapy under a doctor's referral and control is more likely to be lumped as part of medical specials than therapy that was not recommended.

If a doctor prescribes medication, the injured party will more easily convince the responsible party that the injuries are serious depending on how strong and how long the medication is prescribed. Taking prescription drugs indicates that a doctor viewed the injury as painful.

Continue reading "Right of Publicity" »

According to a Chicago Tribune article "Tribune Co. creditors sue banks over buyout" on March 4, 2010, Tribune Co. creditors filed lawsuits against banks behind Tribune Co.'s 2007 leveraged buyout, claiming the $8 billion in loans arranged prompted the company to bankruptcy. Tribune Co. announced in December 2008 that it was voluntarily restructuring its debt obligations under the protection of Chapter 11 of the U.S. Bankruptcy Code in the United States Bankruptcy Court for the District of Delaware.

Tribune Co. is an example of a bankruptcy and restructuring case, where a court is asking whether unsuccessful leveraged buyouts (LBOs) constitute fraudulent transfers by the lenders or equity purchasers. A LBO occurs when a financial sponsor acquires a controlling interest in a company's equity and a percentage of the purchase price is financed through leverage (defined as borrowing). The assets of the acquired company are used as collateral for the borrowed capital.

Fraudulent transfers may involve actual or constructive fraud. Bankruptcy Code Section 548 provides standards for avoiding fraudulent transfers. Each state has its own fraudulent transfer law. Bankruptcy Code Section 544 incorporates state fraudulent transfer law.

Bankruptcy Code Section 548(a) gives the actual fraud standard. A debtor may avoid any transfer of the debtor's property, or any obligation incurred by the debtor, that was made or incurred on or within two years before the debtor filed for bankruptcy, if the debtor voluntarily or involuntarily made such transfer or incurred such obligation with "actual intent to hinder, delay or defraud" a creditor.

Bankruptcy Code Section 548(a)(1)(B) discusses constructive fraud. The Code allows avoiding any transfer where the debtor received "less than a reasonably equivalent value in exchange for such transfer or obligation" and either was: (I) insolvent on the date such transfer was made or obligation incurred, or became insolvent as a result of such transfer or obligation; (II) engaged in business or a transaction, or about to engage in business or a transaction, for which any property remaining with the debtor was an unreasonably small capital; (III) intended to incur, or believed that the debtor would incur, debts that would be beyond the debtor's ability to pay as such debts matured; or (IV) made such transfer to or for the benefit of an insider, or incurred such obligation to or for the benefit of an insider, under an employment contract and not in the ordinary course of business.

Continue reading "Fraudulent Transfers" »

The Bankruptcy Court for the Southern District of New York confirmed the plan of reorganization of Crabtree & Evelyn, Ltd. in January 2010. The company filed bankruptcy around July 1, 2009 as reported by Rachel Feintzeig of The Wall Street Journal "Crabtree & Evelyn Files for Bankruptcy Protection". Crabtree & Evelyn, retailer of body and home products, is among the numerous U.S. retailers who have filed Chapter 11 bankruptcy protection. Many retailers who file bankruptcy do not successfully reorganize.

Crabtree & Evelyn closed on a $26.3 million exit loan from its parent company, Kuala Lumpur Kepong Berhad, a Malaysian company that also owns palm and rubber tree plantations. This loan provides cash to make payments under the plan of reorganization and pay amounts towards the company's strategic business plan. The company has resized its retail footprint by closing 35 of its retail locations and focusing on the remaining 91 retail locations. The company launched an e-commerce platform, at www.crabtree-evelyn.com.

Crabtree & Evelyn has introduced new products as part of its execution on its plans, such as the new Citron Honey & Coriander Hand Therapy Collection, naturally based hand creams, cleansers, and treatments.

There is a Crabtree & Evelyn located at 2 Embarcadero Center, Street Level in San Francisco, CA that markets it as a place that soothes the mind, body and soul.

Continue reading "Crabtree & Evelyn, Ltd." »