On November 4, 2019, Patrick O’Keefe and O’Keefe and Associates Consulting, LLC (the “Receiver”), through their counsel, Jaffe, Raitt, Heuer & Weiss, P.C. filed a motion seeking authority to make a first distribution of funds to the creditors holding Allowed Claims and to correct the Allowed Amount of five creditor’s claims. The Receiver is proposing to make an initial distribution in the aggregate amount of $200,000 to certain of the creditors. The amount each creditor will receive is set forth on Exhibit 1, opposite their name. Click here to view Exhibit 1 of the motion.

The initial distribution will allow those creditors who have received a distribution of less than 7.28 percent to receive a distribution to bring them up to a total 7.28 percent distribution. Not all creditors are receiving the same percentage distribution (in fact, very few creditors are receiving the same percentage) based on the application of the “Rising Tide” methodology described in the motion.

This is the first distribution from the Receivership Estates. As additional properties are sold, one or more additional distributions will be made.

Please take notice that a hearing on the motion shall be heard on December 11, 2019 at 3:00 p.m. in the courtroom of the Honorable Marianne Battani, 231 West Lafayette Blvd., Room 252, Detroit, Michigan 48226.

If you agree with the relief sought in the Motion, there is no need for you to attend. If you disagree with the relief sought in the Motion, you should attend and express your opposition and to the extent you desire to do so, file a written opposition.

Creditors are encouraged to contact Julie Norton, at Jaffe, Raitt, Heuer & Weiss, P.C., 248-351-3000 or by email to, with any questions related to this Motion or the proposed distribution to a given creditor.

To read the Motion for Order Authorizing First Distribution, click here.