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Museum Plan

Museum Plan

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Published by melaniel_co

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Published by: melaniel_co on Feb 21, 2012
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Sandra R. Robinson, VSB #31885Robinson Law & Consulting Firm, P.C.P.O. Box 503Richmond, Virginia 23218(804) 928-5458(804) 303-3499 [fax]
Counsel for Debtor 
UNITED STATES BANKRUPTCY COURTEASTERN DISTRICT OF VIRGINIARichmond DivisionIn re: Chapter 11United States National Slavery Museum Case No. 11-36013-DOTaka U.S. National Slavery Museum
The Plan provides for the Debtor to reinstate its fundraising efforts to provide for thepublic display of its artifacts and other historical items and documents in its own building on itsown land. After paying all the pre-petition debts and the administrative expenses, including suchthings as judgments, and after reserving for additional expenditures, the Debtor commits its netoperating income to the payment of all filed Claims. The Claims will be paid as follows:
Secured Claim of Pei Partnership
shall be paid to the extent of its judgment at the time of entry, in full within four years after receiving its first payment, while receiving interestpayments.
Secured Claim of City of Fredericksburg s
hall be paid in full within four years afterreceiving its first payment. This claim is impaired.
General Unsecured Claims
held by any Person other than an Insider shall be paid in the fullamount of the Allowed Claims, receiving four yearly distributions on the first day of eachquarter, beginning October 1, 2012.
Case 11-36013-DOT Doc 46 Filed 02/17/12 Entered 02/17/12 23:29:00 Desc MainDocument Page 1 of 33
Unsecured Claims
held by Insiders shall be paid after all other Allowed Claims have beenpaid in full.Other alternatives available to the Debtor or which might be imposed upon the Debtor bycertain of their secured creditors would not provide for an orderly reorganization of the Debtor ina manner that would maximize its value for the benefit of all creditors. The liquidationalternatives analyzed by the Debtor demonstrate that a complete return to all creditors is possibleonly if (1) the Debtor is able to generate revenue consistent with the minimum annual level of donations it received prepetition and are utilized in connection with the further development of the Property, (2) the Debtor restructure its indebtedness and (3) the Debtor utilize its netoperating income to repay their indebtedness.The Debtor’s board of directors is committed to the success of the Debtor. As evidence of theircommitment to the Plan and the success of the Debtor’s reorganization, the Insiders have agreedthat they will accept no payment, on account of any Unsecured Claim, until all other AllowedClaims have been paid in full.
The Debtor asks that you carefully consider this Plan and cast a ballot in favor of the Plan.ARTICLE I
Defined Terms
Any term in the Disclosure Statement or Plan that is defined in §§ 101, 102 or 1101 of the Bankruptcy Code shall have the meaning assigned therein. The following terms, where theyare used in the Disclosure Statement and in the Plan, shall have the meanings hereinafterassigned.
Case 11-36013-DOT Doc 46 Filed 02/17/12 Entered 02/17/12 23:29:00 Desc MainDocument Page 2 of 33
Administrative Bar Date:
The date by which all Persons assertingAdministrative Expense Claims arising before the Effective Date must have filed such claim, asmay be fixed by Order of the Bankruptcy Court.2.
Administrative Expense Claim(s):
Any right to payment for the costs andexpenses of this Case, including: (a) the actual, necessary costs and expenses of preserving theDebtor’s estate and operating the businesses of the Debtor, (b) all allowances of compensationand reimbursement of costs and expenses under §§ 330 or 502 of the Bankruptcy Code, or (c) ormay be otherwise authorized by an Order of the Court. Except for the filing fee required tocommence this Case, administrative expense claim(s) shall be limited to debts and expenses thathave been incurred post-petition.3.
Concerning a claim against or an equity security interest in any of theDebtor, such a claim or interest to the extent that (a) a proof of claim or interest was timely filedand to which no objection has been filed, or (b) a proof of claim was deemed filed pursuant to §1111 (a) of the Bankruptcy Code, and such claim was not listed by any of the Debtor as disputed,contingent or unliquidated in its list of creditors filed with the Court pursuant to BankruptcyCode § 521 (a)(1), or (c) a proof of claim, to which an objection has been filed, or other claim orequity security interest, which is allowed by an Order of the Court.4.
Bankruptcy Code and/or Code:
Title 11, United States Code, as in effect on theFiling Date, and all amendments thereto which apply to this Case.5.
Bankruptcy Claim(s):
Any and all actions, claims, rights, defenses, third-partyclaims, cross-claims, counterclaims, suits, causes of action, chooses in action, controversies,agreements, promises, rights to legal remedies, rights to equitable remedies, and rights topayment, whether known, unknown, which the Trustee, a debtor-in-possession, the bankruptcy
Case 11-36013-DOT Doc 46 Filed 02/17/12 Entered 02/17/12 23:29:00 Desc MainDocument Page 3 of 33

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