Claims Against Apparel Manufacturing Company

Sale of claims against Magic Apparel Group which includes:

1. the State Court Action Claims: the Case Trustees assert that some, if not all, of the pre-petition fraudulent transfer claims asserted by Cathay in the State Court Action (the “State Court Action Claims”) are property of either the Individual Bankruptcy Estate or the Company Bankruptcy Estate (or perhaps, in some cases, both Bankruptcy Estates) and that only the respective chapter 7 trustee has standing to assert the State Court Action Claims. Cathay disagrees with this position of the Case Trustees and asserts that at least some of the State Court Action Claims belong to Cathay, and that Cathay has standing to continue to prosecute the State Court Action. Kurtz Decl., ¶ 11.
2. the Avoidance Claims: the Case Trustees assert that the Bankruptcy Estates possess claims pursuant to sections 544, 547, 548, and 550 (including without limitation claims pursuant to section 550(b)) of the Bankruptcy Code against persons named as defendants in the State Court Action or the affiliates, insiders, or successors of such persons, or the initial or subsequent transferees of such persons.
3. the Stuart Whang Claims: the Case Trustees assert that the Bankruptcy Estates have additional valuable claims against (i) Stuart Whang, the Individual seller’s brother; and (ii) SWW Investment, LLC, a California limited liability Individual (“SWW”). The Individual Trustee understands that Stuart Whang owns one hundred percent (100%) of the equity in SWW. The Bankruptcy Estates’ claims against these parties consist of claims of any type, including pursuant to sections 544, 547, 548, and 550 of the Bankruptcy Code, against Stuart Whang, SWW or any affiliates of Stuart Whang or SWW or the affiliates, insiders, or successors of such persons, or the initial or subsequent transferees of such persons.
4. the Global Claims: the Case Trustees and Cathay believe that the Magic Apparel owns Global Apparel Group Co., Ltd, a Vietnamese Company (“Global Apparel Group”). The Case Trustees and Cathay further believe that in or about September 2015, Global Apparel Group changed its name to South East Apparel Group Co., Ltd. (“South East”). The Case Trustees believe that the Individual Bankruptcy Estate, the Company Bankruptcy Estate, or both Bankruptcy Estates possess ownership rights in Global Apparel Group and/or South East, and further hold claims against Global Apparel Group and/or South East, their affiliates, insiders, or successors of such person or entity, or the initial or subsequent transferees of such person or entity.