Loading...
HomeMy WebLinkAbout982113.tiff WELD COUNTY UNITED STATES BANKRUPTCY COURT �" ' nc SOUTHERN DISTRICT OF NEW YORK !°? CCI 22 AM 8: 38 x CLERK In re: 186A D CITYSCAPE FINANCIAL CORP., Case Nos. 98-B-22569 (ASH) Tax I.D. No. 11-2994671, and and 98-B-22570 (ASH) CITYSCAPE CORP., Jointly Administered Tax I.D. No. 13-3430697, : Hearing Date: November 13, 1998 Debtors. : at 9:30 a.m. x NOTICE OF HEARING TO CONSIDER APPROVAL OF DISCLOSURE STATEMENT AND SOLICITATION PROCEDURES AND CONFIRMATION OF THE DEBTORS' PLAN OF REORGANIZATION NOTICE IS HEREBY GIVEN THAT: 1. On October 6, 1998, Cityscape Financial Corp. and Cityscape Corp. (collectively, the "Debtors") whose principal place of business is 565 Taxter Road, Elmsford, New York 10523, commenced in the United States Bankruptcy Court for the Southern District of New York (the "Bankruptcy Court") voluntary cases under chapter 11 of title 11 of the United States Code (the "Bankruptcy Code") and filed concurrently therewith, as debtors and debtors-in- possession, the joint Plan of Reorganization of the Debtors dated October 6, 1998 (the "Plan") and a Solicitation and Disclosure Statement dated August 28, 1998 (the"Disclosure Statement") relating to the Plan. Copies of the Plan and Disclosure Statement are on file with the Clerk of the Bankruptcy Court for the Southern District of New York, 300 Quarropas Street, White Plains, New York 10601-5008 and may be reviewed during the Court's regular business hours. Copies of the Plan and Disclosure Statement may also be obtained from Bondholder Communications Group, 30 Broad Street, 46th Floor,New York, New York 10004, (212) 809-2663, Attention: John Farr. 2. Beginning on August 29, 1998, prior to the commencement of the Debtors' chapter 11 cases and in reliance upon section 1145 of the Bankruptcy Code, section 3(a)(9) of the Securities Act of 1933, as amended, and section 4(2) of the Securities Act of 1933, as amended, and Regulation D promulgated thereunder, the Debtors solicited votes for the acceptance or rejection of the Plan from the holders of their 12-3/4% Series A Senior Notes due 2004 (the "Senior Noteholders"), the holders of their 6% Convertible Subordinated Debentures V ),, , `' j �:_ / / s 982113 ��� ,F)'' ' ., • , due 2006 (the "Subordinated Debentureholders") and the holders of their 6% Convertible Preferred Stock, Series A and Series B (the "Preferred Stockholders"). The Senior Noteholders, the Subordinated Debentureholders and the Series A Preferred Stockholders voted overwhelmingly in favor of the Plan, in accordance with the requirements of section 1126(b) of the Bankruptcy Code. 3. Attached to this Notice as Exhibit "I" is a summary of the Plan. 4. A hearing to consider confirmation of the Plan, including approval of the Disclosure Statement and the solicitation procedures used in connection therewith, and any objections that may be interposed thereto and any other matter that may properly come before the Bankruptcy Court will be held before the Honorable Adlai S. Hardin Jr., United States Bankruptcy Judge, United States Bankruptcy Court for the Southern District of New York, 300 Quarropas Street, 5th Floor, White Plains,New York 10601-5008 on November 13, 1998, at 9:30 a.m. (New York City Time) or as soon thereafter as counsel may be heard (the "Confirmation Hearing"). The Confirmation Hearing may be adjourned from time to time without further notice other than an announcement of the adjourned date or dates at the Confirmation Hearing or at an adjourned hearing. 5. Any objection to the Plan shall be in writing, shall state the name of the objector, its interest in the chapter 11 cases, and, if appropriate, the amount and nature of its claim, that it is an objection to the confirmation of the Plan, as well as the grounds for the objection and the legal basis therefor, and be filed with the Bankruptcy Court, and served upon and received by the parties listed below, together with proof of service, on or before November 9, 1998 at 5:00 p.m. (New York City Time): (1) CITYSCAPE FINANCIAL CORP. CITYSCAPE CORP. 565 Taxter Road Elmsford,NY 10523-2300 Attn: Steven M. Miller (2) LATHAM & WATKINS Attorneys for the Debtors 885 Third Avenue, Suite 1000 New York, NY 10022 Attn: Robert J. Rosenberg, Esq. (3) KASOWITZ, BENSON,TORRES & FRIEDMAN,LLP Attorneys for the Unofficial Senior Noteholders' Committee 1301 Avenue of the Americas New York,NY 10019 Attn: David M. Friedman, Esq. 2 (4) KRAMER, LEVIN, NAFTALIS & FRANKEL Attorneys for the Unofficial Subordinated Debentureholders' Committee 919 Third Avenue New York, NY 10022 Attn: Kenneth H. Eckstein, Esq. (5) OFFICE OF THE UNITED STATES TRUSTEE 33 Whitehall Street, 21st Floor New York, New York 10004 UNLESS AN OBJECTION IS TIMELY SERVED AND FILED IN ACCORDANCE WITH THIS NOTICE, THE OBJECTION WILL NOT BE CONSIDERED BY THE BANKRUPTCY COURT. Dated: October 7, 1998 LATHAM & WATKINS By: \s\ Robert J. Rosenberg Robert J. Rosenberg (RJR 9585) A. Brent Truitt(ABT 3799) Rachael Fink (RF 3321) 885 Third Avenue, Suite 1000 New York,New York 10022 (212) 906-1200 Counsel for the Debtors and Debtors-in- Possession 3 1//3 EXHIBIT I SUMMARY OF PLAN OF REORGANIZATION The basis of the Plan is a complete conversion (subject to a limited issue of$75 million in principal amount of New Senior Notes(as defined below))to common equity(or rights to acquire common equity)of the Old Senior Notes,the Old Subordinated Debentures,the Old Series A Preferred Stock and the Old Series B Preferred Stock (each as defined below). Material features of the Plan are summarized below and a chart summarizing the treatment of each class of claims and interests under the Plan can be found at the end of this summary. Senior Secured Indebtedness Prior to the date (the "Petition Date") they commenced their chapter 11 cases, Cityscape Financial Corp. ("Cityscape") and Cityscape Corp. ("CSC" and, together with Cityscape,the"Company" or the"Debtors")entered into two secured credit facilities,referred to in the Plan as the Greenwich Facility and the CIT Facility. Subject to Bankruptcy Court approval,on or about the Petition Date (or such other date as the Bankruptcy Court permits such payment), the Greenwich Facility and the CIT Facility will be repaid by the Company using the proceeds of the respective DIP Facilities(as defined below). The Company has requested and received separate commitments for debtor in possession financing in the aggregate of up to $250 million from three lenders. Greenwich Capital Financial Products,Inc.,an affiliate of Greenwich Capital Markets, Inc. (together with any such affiliates "Greenwich") has committed to provide up to $100 million in the form of a revolving credit facility(the "Greenwich DIP Facility") and The CIT Group/Business Credit,Inc.and/or its affiliates("CIT")and Nomura Asset Capital Corporation and/or its affiliates("Nomura") have together committed to provide up to $150 million in the form of a revolving credit facility(the "CIT/Nomura DIP Facility" and collectively, with the Greenwich DIP Facility, the "DIP Facilities").Subject to the approval of the Bankruptcy Court, the Company will use the funds provided by Greenwich to repay all amounts outstanding under the Greenwich Facility and to operate its business during the pendency of Cityscape's and CSC's chapter I 1 cases (the "Reorganization Cases"). Subject to the approval of the Bankruptcy Court, the Company will use the funds provided by CIT and Nomura to repay all amounts outstanding under the CIT Facility and to operate its business during the pendency of the Reorganization Cases. To the extent that the Claims of Greenwich and CIT are not satisfied by the DIP Facilities or otherwise, such claims will be paid in full in cash on the effective date of the Plan(the"Effective Date"). I or Notes e 04 (including principal and accrued interest) ("Old Senior Old Senior Notes............................................................. Cityscape'swill l be° Series A converted into e etach holder's pro 0rata Notes") 178778 F3o. portion(sharing with all other such holders)of(i)shares (CUSIP178778AF3) of $0.01 par value common stock of Reorganized Cityscape ("New Common Stock") equivalent to 90.5% of the New Common Stock to be outstanding on the Effective Date,and(ii)9.25%Senior PIK Notes due 2008 issued by Reorganized Cityscape ("New Senior Notes") representing Senior Notes to be outstanding as of the Effective Date. ew Ci sca e's 6%Convertible Subordinated Debentures due 2006("Old Subordinated Debentures") will be converted Old Subordinated Debentures......................................... Ty p of 9.5% of [he New into each holder's pro rata portion 178778 Nos. Common Stock to be outstanding as of the Effective Date (CUSIP78778AB2A4 and,provided that the class of such holders votes to accept 178778AC0 the Plan, such holder's pro rata portion of warrants to 178778A ) purchase 5%of the New Common Stock on a fully diluted $ with a five ("Nematurity% and an exercise. pass of ice of $19.31 per f share e Old of the Subordinated Debentures voted to accept the Plan;therefore,such holders would receive the New 5%Warrants under the Plan. Cit sca e's 6% Convertible Preferred ill be Series A ("Old Series A Preferred Stock") roxie cv converted into Old Series A Preferred Stock.......................................... Y each holder's pro rata portion of app of the"New 10%Warrants," which are warrants to purchase New Common Stock representing 10% of the New Common Stock on a fully diluted basis;provided,that the class of such holders votes to accept the Plan and no class senior to such class votes(or is deemed to have voted)to reject the Plan. The class of holders of Old Series A Preferred Stock voted to accept the Plan and classes senior to such class voted topccept Preferred Stock would the Plan;therefore,holders Old eceive Series A approximately 10.3%of the New 10%Warrants under the Plan. The New 10% Warrants will have a five year maturity and an exercise price of$27.86 per share. .. Cityscape's 6%Convertible Preferr'dbe Stock rt Series Old Series B Preferred Stock.................. ("Old Series B Preferred Stock") roxie cv converted into each holder's pro rata portion of app of the New 10% Warrants;provided, that the class of such holders votes to accept the Plan and no class senior to such class votes(or is deemed to have voted)to reject the Plan. The class of holders of Old Series B Preferred Stock voted to reject the Plan; therefore,such holders will not receive any distributionsunder the Plan. 2 QM//3 For Each$1,000 Principal Amount Based Upon the Votes on the Plan, or Liquidation Preference,as Applicable,of: Each Holder Will Receive: Old Senior Notes 38.4625 shares of New Common Stock and $250.00 in initial principal amount in New Senior Notes. Old Subordinated Debentures 9.3446 shares of New Common Stock and New 5%Warrants to purchase 5.7861 shares of New Common Stock. Old Series A Preferred Stock New 10%Warrants to purchase approximately 20.76 shares of New Common Stock. Old Series B Preferred Stock No distribution. Other Terms of the Plan Under the Plan, secured claims and general unsecured claims (excluding claims based upon the Old Senior Notes and Old Subordinated Debentures) are unimpaired and, to the extent not paid during the pendency of the Reorganization Cases, will receive treatment that the Bankruptcy Court determines to constitute"unimpairment." Except as otherwise provided in the Plan or the order confirming the Plan (the "Confirmation Order") (i) on the Effective Date,the Debtors shall be deemed discharged and released to the fullest extent permitted by Section 1141 of the Bankruptcy Code from all claims against and interests in them that arose before the Effective Date, and (ii) all persons shall be precluded from asserting against Reorganized Cityscape, Reorganized CSC, their respective successors, or their respective assets or properties any other or further claims or interests based upon any act or omission,transaction,or other activity of any kind or nature that occurred prior to the Effective Date. None of the Debtors, Reorganized Cityscape, Reorganized CSC, the members of the Unofficial Senior Noteholders' Committee, the members of the Unofficial Subordinated Debentureholders' Committee, the members of any Creditors' Committee appointed in these cases, the indenture trustees under the indentures governing the Old Senior Notes and Old Subordinated Debentures (the "Indenture Trustees"), CIT, Greenwich or any of their respective employees, officers,directors, agents, or representatives,or any professional persons employed by any of them, shall have any responsibility, or have or incur any liability, to any person whatsoever (i) for any matter expressly approved or directed by the Confirmation Order or(ii) under any theory of liability (except for any claim based upon willful misconduct or gross negligence) for any act taken or omission made in good faith directly related to formulating, implementing, confirming, or consummating the Plan, the Disclosure Statement, or any contract, instrument, release, or other agreement or document created in connection with the Plan. On the Effective Date, each of the Debtors will release (i) each of the Debtors' then-current and former officers, directors, shareholders, employees, consultants, attorneys, accountants, financial advisors and other representatives (solely in their capacities as such) (collectively, the "Debtor Releasees"), (ii) any Creditors' Committee appointed in these cases and each member,consultant, attorney, accountant or other representative of the Creditors' Committee, (iii) the Unofficial Senior Noteholders' Committee and each member, consultant, attorney, accountant or other representative of the Unofficial Senior Noteholders' Committee, (iv) the Unofficial Subordinated Debentureholders' Committee and each member, consultant, attorney, accountant or other representative of the Unofficial Subordinated Debentureholders' Committee, (v) the Indenture Trustees, (vi) CIT and Greenwich and each of their then-current and former officers, directors, shareholders, employees, consultants, attorneys, accountants, financial advisors and other representatives from any and all claims, obligations, suits, judgments, damages, rights, causes of action and liabilities whatsoever, whether known or unknown, foreseen or unforeseen, existing or hereafter arising, in law, equity or otherwise, based in whole or in part upon any act or 3 98/13 omission,transaction, event or other occurrence taking place on or prior to the Effective Date in any way relating to Cityscape, CSC, the Company's trust indentures, the CIT Facility, the Greenwich Facility, the DIP Facilities, the Debtors,the Reorganization Cases,the Plan or the Disclosure Statement. On the Effective Date, each holder of a claim against or interest in the Debtors shall be deemed to have unconditionally released the Debtor Releasees from any and all claims, obligations, suits, judgments, damages, rights,causes of action and liabilities whatsoever which any such holder may be entitled to assert,whether known or unknown, foreseen or unforeseen, existing or hereafter arising, in law,equity or otherwise, based in whole or in part upon any act or omission,transaction,event or other occurrence taking place on or prior to the Effective Date in any way relating to Cityscape, CSC, the Company's trust indentures, the Debtors,the Reorganization Cases, the Plan or the Disclosure Statement. 4 9��rr3 The following chart summarizes the treatment for creditors and shareholders of Cityscape and CSC under the Plan. Estimated recoveries for creditors and shareholders under the Plan are based upon(i)in the case of claims, principal and accrued and unpaid interest as of September 30, 1998, and(ii) in the case of preferred equity interests, liquidation preference as of such date. CLAIMS AGAINST AND INTERESTS IN CITYSCAPE Estimated Class Description Treatment Recovery N/A Administrative Claims(Unclassified) Each holder will be paid cash equal to the full amount of 100% its claim on,or as soon as practicable after,the later of the Effective Date and the day on which such claim becomes an allowed claim,unless(i)the holder and the Company, Reorganized Cityscape or Reorgan ized CSC,as the case may be,agree to other treatment,or(ii)an order of the Bankruptcy Court provides for other terms. N/A Priority Tax Claims(Unclassified) Each holder will receive,at the sole option of Reorganized 100% Cityscape or Reorganized CSC,as the case may be, (i)cash equal to the unpaid portion of such holder's claim, or(ii)equal quarterly cash payments in an aggregate amount equal to such claim,together with interest at a fixed annual rate to be determined by the Bankruptcy Court or otherwise agreed to by the holder and Reorganized Cityscape or Reorganized CSC,as the case may be,over a period through the sixth anniversary of the date of assessment of such claim,or upon other terms approved by the Bankruptcy Court. Al Bank Claims(under the Greenwich Unimpaired Subject to Bankruptcy Court approval,each 100% Facility and the CIT Facility) holder will be paid in full prior to the Effective Date with the proceeds of debtor in possession financing facilities. To the extent there are any allowed Bank Claims as of the Effective Date,each holder of an allowed Bank Claim will be paid in full in cash on the Effective Date.Class A 1 is Unimpaired and,accordingly,was not entitled to vote on the Plan. A2a et Other Secured Claims(other than Unimpaired. Either(i)the claim will be left unaltered, 100% seq. Secured Claims in Class Al) (ii)any default with respect thereto(other than a default of a kind specified in Section 365(b)(2)of the Bankruptcy Code)will be cured,the maturity thereof will be reinstated and the holder thereof will be compensated for any damages,or(iii)the claim will receive such other treatment to which the holder consents. Class A2a et seq. is Unimpaired and,accordingly,was not entitled to vote on the Plan. A3 Priority Claims(i.e.,those entitled to Unimpaired Each holder will receive cash equal to the 100% priority under the Bankruptcy Code) amount of such claim,or such other treatment,as determined by the Bankruptcy Court,required to render such claim Unimpaired.Class A3 is Unimpaired and, accordingly,was not entitled to vote on the Plan. 5 Q&O? 1/3 Estimated Class Description Treatment Recovery, A4 Old Senior Note Claims Impaired Each holder will receive a pro rata portion of 46.5% the New Senior Notes((e.,$250.00 of original principal amount of New Senior Notes for each$1,000 of principal amount of Old Senior Notes)and a pro rata portion of 90.5%of the New Common Stock(i.e., 38.4625 shares of New Common Stock for each$1,000 of principal amount of Old Senior Notes)to be issued by Reorganized Cityscape.Class A4 is Impaired and, accordingly, holders of such claims were entitled to vote on the Plan. Class A4 voted to accept the Plan. A5 General Unsecured Claims(other than the Unimpaired. Such claims will either not be altered under 100% Unsecured Claims in Classes A4,A6,A7, the Plan or,at the option of the Company,receive such A9,A I I,A 13 and A14) other treatment that will result in such claims being deemed Unimpaired.Class A5 is Unimpaired and, accordingly,was not entitled to vote on the Plan. A6 Old Subordinated Debenture Claims Impaired Each holder will receive a pro rata portion of 9.4% 9.5%of the New Common Stock to be issued by Reorganized Cityscape(i.e.,9.3446 shares of New Common Stock for each$1,000 of principal amount of Old Subordinated Debentures)and a pro rata portion of the New 5%Warrants(i.e.,warrants to purchase 5.7861 shares of New Common Stock for each$1,000 of principal amount of Old Subordinated Debentures); provided,however,that no New 5%Warrants will be distributed if Class A6 does not vote to accept the Plan. Class A6 is Impaired and,accordingly,holders of such claims were entitled to vote on the Plan. Class A6 voted to accept the Plan;therefore,the New 5%Warrants will be distributed to Class A6. A7 Securities Claims' on Account of Old Impaired Holders will not receive or retain any interest 0% Senior Notes or Old Subordinated or property under the Plan and are,therefore,deemed to Debentures have rejected the Plan. Accordingly,Class A7 was not entitled to vote on the Plan.The Company is not aware of any Class A7 claims. A8 Interests of Holders of Old Series A Impaired. Each holder will receive a pro rata portion of 4.8% Preferred Stock approximately 10.3%of the New 10%Warrants(i.e., warrants to purchase approximately 20.76 shares of New Common Stock for each$1,000 in liquidation preference); provided,that Class A8 and classes senior to Class A8 vote to accept the Plan. Class A8 is Impaired and, accordingly,was entitled to vote on the Plan. Class A8 "Securities Claim"means(a)any claim arising from rescission of a purchase or sale of Old Senior Notes, Old Subordinated Debentures,Old Cityscape Common Stock,Old Series A Preferred Stock,Old Series B Preferred Stock or warrants to purchase Old Cityscape Common Stock("Old Warrants")or for damages arising from the purchase or sale of any of such securities(collectively,"Old Securities")or(b)any claim for indemnity, reimbursement or contribution on account of any such claim. 6 Estimated Class Description Treatment Recovery voted to accept the Plan and classes senior to Class A8 voted to accept the Plan;therefore,approximately 10.3% of the New 10%Warrantswill be distributed to Class A8. A9 Securities Claims on Account of Old Impaired. Holders will not receive or retain any interest 0% Series A Preferred Stock or property under the Plan and are,therefore,deemed to have rejected the Plan. Accordingly,Class A9 was not entitled to vote on the Plan.The Company is not aware of any Class A9 claims. A10 Interests of Holders of Old Series B Impaired Each holder will receive a pro rata portion of 4.8%` Preferred Stock approximately 89.7%of the New 10%Warrants(i.e., warrants to purchase approximately 20.76 shares of New Common Stock for each$1,000 in liquidation preference); provided,that Class A I 0 and classes senior to Class A I 0 vote to accept the Plan.Class A10 is Impaired and, accordingly,was entitled to vote on the Plan. Because Class A 10 voted to reject the Plan,Class A10 will not receive any distribution under the Plan. All Securities Claims on Account of Old Impaired. Holders will not receive or retain any interest 0% Series B Preferred Stock or property under the Plan and are,therefore,deemed to have rejected the Plan. Accordingly,Class All was not entitled to vote on the Plan. Al2 Interests of Holders of Old Cityscape Impaired Holders will not receive or retain any interest 0% Common Stock or property under the Plan and are,therefore,deemed to have rejected the Plan. Accordingly,Class A 12 was not entitled to vote on the Plan. A l3 Interests of Holders of Old Stock Rights' Impaired Holders will not receive or retain any interest 0% in Cityscape and all Claims Arising Out of or property under the Plan and are,therefore,deemed to Such Old Stock Rights have rejected the Plan. Accordingly,Class A 13 was not entitled to vote on the Plan. Al4 Securities Claims on Account of Old Impaired. Holders will not receive or retain any interest 0% Cityscape Common Stock and Old or property under the Plan and are,therefore,deemed to Warrants have rejected the Plan. Accordingly,Class A 14 was not entitled to vote on the Plan. 2 However,because Class A10 voted to reject the Plan,no distributions will be made to Class A10 and the actual recovery for Class Al0 will be 0%. 3 "Old Stock Rights"means,collectively,Old Warrants, and any other rights or options to purchase or otherwise acquire Old Securities, and any stock appreciation or similar rights relating to Old Securities, existing prior to the Effective Date. 7 ;?//3 CLAIMS AGAINST AND INTERESTS IN CSC Estimated Class Description Treatment Recovery B Bank Claims(under the Greenwich Unimpaired. Subject to Bankruptcy Court approval,each 100% Facility and the CIT Facility) holder will be paid in full prior to the Effective Date with the proceeds of debtor in possession financing facilities. To the extent there are any allowed Bank Claims as of the Effective Date,each holder of an allowed Bank Claim will be paid in full in cash on the Effective Date.Class B1 is Unimpaired and,accordingly,was not entitled to vote on the Plan. B2a et Other Secured Claims(other than Secured Unimpaired. Either(i)the claim will be left unaltered,(ii) 100% sea Claims in Class BI) any default with respect thereto(other than a default of a kind specified in Section 365(6)(2)ofthe Bankruptcy Code)will be cured,the maturity thereof will be reinstated and the holder thereof will be compensated for any damages,or(iii)the claim will receive such other treatment to which the holder consents. Class B2a et seq. is Unimpaired and,accordingly,was not entitled to vote on the Plan. B3 Priority Claims(i.e.,those entitled to Unimpaired. Each holder will receive cash equal to the 100% priority under the Bankruptcy Code) amount of such claim,or such other treatment,as determined by the Bankruptcy Court,required to render such claim Unimpaired. Class B3 is Unimpaired and, accordingly,was not entitled to vote on the Plan. B4 Claims of Holders of Old Senior Notes Impaired. Each holder w ill receive a new guaranty by N/A Based Upon CSC's Guarantee of Old Reorganized CSC of Reorganized Cityscape's obligations Senior Notes under the New Senior Notes pursuant to the terms of the indenture governing the New Senior Notes and any related documents or agreements.Class B4 is Impaired and,accordingly,was entitled to vote on the Plan. Class B3 voted to accept the Plan. B5 General Unsecured Claims(other than the Unimpaired. Such claims will either not be altered under 100% Unsecured Claims in Classes B4 and B6) the Plan or,at the option of the Company,receive such other treatment that will result in such claims being deemed Unimpaired.Class B5 is Unimpaired and, accordingly,was not entitled to vote on the Plan. B6 Intercompany Claims(of Cityscape Unimpaired. Such claims will either not be altered under 100% against CSC) the Plan or,at the option of Cityscape,receive such other treatment that will result in such claims being deemed Unimpaired.Class B6 is Unimpaired and,accordingly, was not entitled to vote on the Plan. B7 Cityscape's 100%Interest in CSC Unimpaired. Cityscape's rights will not be altered under 100% the Plan.Class B7 is Unimpaired and,accordingly,was not entitled to vote on the Plan. 8 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK x In re: Chapter 11 CITYSCAPE FINANCIAL CORP., Case Nos. 98-B-22569 (ASH) Tax I.D. No. 11-2994671, and and 98-B-22570 (ASH) CITYSCAPE CORP., Jointly Administered Tax I.D.No. 13-3430697, • Debtors. x NOTICE OF COMMENCEMENT OF CASES AND MEETING OF CREDITORS AND EQUITY SECURITY HOLDERS NOTICE IS HEREBY GIVEN, THAT: 1. COMMENCEMENT OF CASES. On October 6, 1998, Cityscape Financial Corp ("Citiscape") and Cityscape Corp. ("CSC"), as debtors and debtors-in- possession in the above-captioned chapter 11 cases (collectively, the "Debtors"), whose principal place of business is 565 Taxter Road, Elmsford, New York 10523, filed petitions for reorganization under chapter 11 of title 11 of the United States Code (the "Bankruptcy Code") with the Clerk of this Court. Pursuant to sections 1107(a) and 1108 of the Bankruptcy Code, the Debtors are authorized to continue to operate their business and manage their properties as debtors and debtors-in-possession. Pursuant to an order of this Court dated October 7, 1998, the above-captioned cases are being jointly administered. 2. MEETING OF CREDITORS. A first meeting of the Debtors' creditors pursuant to section 341(a) of the Bankruptcy Code (the "341 Meeting")will be held on November 10, 1998, at 10:00 a.m. at the United States Courthouse, 300 Quarropas Street, White Plains 10601-5008, Room 243A. You are invited to attend but need not do so; your rights will not be prejudiced if you do not attend. The United States Trustee, as specified in Rule 9001(11) of the Federal Rules of Bankruptcy Procedure (the `Bankruptcy Rules"), will convene and preside at the 341 Meeting. The Debtors, as specified in Bankruptcy Rule 9001(5), will appear at the 341 Meeting. Creditors may examine the Debtors and transact such other business as may properly come before such meeting. The 341 Meeting may be continued or adjourned from time to time by an announcement at the 341 Meeting without further written notice to creditors or other parties in interest. 3. CREDITORS MAY NOT TAKE CERTAIN ACTIONS. As a result of the commencement of the Debtors' chapter 11 cases, all acts and proceedings, among other things, to collect, assess or recover a claim; to enforce a judgment; to obtain possession of property of the Debtors' estates or property from the estates or exercise control over property of the estates; or to create, perfect or enforce a lien against the Debtors or the Debtors' property have been, and continue to be, stayed pursuant to section 362(a) of the Bankruptcy Code. Common examples of prohibited actions by creditors are contacting a debtor to demand repayment, terminating a contract with a debtor, taking action against a debtor to collect money owed to creditors, or taking property of a debtor. If unauthorized actions are taken by a creditor against a debtor, the Court may penalize that creditor. A creditor who is considering taking action against a debtor or the property of a debtor should review section 362 of the Bankruptcy Code and may wish to seek legal advice. The staff of the Clerk of the Bankruptcy Court is not permitted to give legal advice. 4. PROOFS OF CLAIM. Pursuant to Bankruptcy Rule 1007(a), the Debtors have filed with their voluntary petitions lists containing the name and address of each of their creditors and containing the names and addresses of individuals and entities with whom the Debtors have done business in 1997 and 1998 but to whom the Debtors do not believe they are indebted. (The list does not include the Debtors' employees.) The list is available for inspection at the United States Courthouse, 300 Quarropas Street, 2nd Floor, White Plains,New York 10601-5008, and at the offices of the Debtors' counsel, Latham & Watkins, 885 Third Avenue, Suite 1000, New York, New York 10022. Not all creditors will be required to file proofs of claims with the Court. A separate notice specifying the types of claims for which proofs of claim are required to be filed and setting forth the last day for any holder thereof to file a proof of claim and the place to file a proof of claim, either in person or by mail, will be served and published. 2 91a"3 5. PLAN OF REORGANIZATION. Chapter 11 of the Bankruptcy Code enables a debtor to reorganize pursuant to the terms of a plan of reorganization. A plan of reorganization is not effective unless approved by the Court at a confirmation hearing. Simultaneously with commencing their chapter 11 cases, the Debtors filed a joint plan of reorganization. Notice of the hearing for the Court to consider confirmation of such plan is being served and published simultaneously herewith. In the event that either of the chapter 11 cases is dismissed or converted to another chapter of the Bankruptcy Code, notice concerning any such dismissal or conversion will be sent to creditors and interest holders. Each of the Debtors will remain in possession of its property and will continue to operate its business unless a trustee is appointed. Dated: White Plains, New York October 7, 1998 \s\ Cecelia G. Morris Clerk of the Bankruptcy Court United States Courthouse 300 Quarropas Street, 2nd Floor White Plains, New York 10601-5008 LATHAM & WATKINS Robert J. Rosenberg (RJR 9585) A. Brent Truitt (ABT 3799) Rachael Fink (RF 3321) 885 Third Avenue, Suite 1000 New York, New York 10022 (212) 906-1200 Counsel for Debtors and Debtors-in-Possession 3 98 "3 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK 300 QUARROPAS STREET WHITE PLAINS,NY 10601-5085 NOTICE OF ELECTRONIC FILING PROCEDURE Case Name: Cityscape Financial Corp. and Cityscape Corp. Case Numbers: 98-22569(ASH) and 98-22570(ASH) Date Filed: October 6, 1998 Effective October 6, 1998, this case will be docketed exclusively on the Court's Electronic Case Filing System. The system can be accessed via the Internet utilizing an attorney password. In compliance with Federal Rules of Civil Procedure Rule 11 and in accordance with Local Bankruptcy Rule 9011-1, the attorney's password shall constitute the signature of the attorney; therefore, security of a password issued to an attorney is the responsibility of that attorney. An original signed copy of the filing shall be maintained in the attorney's files. A chamber's copy of all filed documents is required and all parties with legal representation must file documents in accordance with the following: 1. The requirements for filing, viewing and retrieving case documents are: A personal computer running a standard platform such as Windows, Windows95 or Macintosh; an Internet provider, Netscape Navigator software version 3.0 or higher and Adobe Exchange software to convert documents from a word processor format to a portable document format (PDF). The URL address is www.nysb.uscourts.gov and a password is needed to access this system. If you are unable to comply with this requirement, then 2. You must submit documents on a diskette using PDF format. The Adobe software will provide this format. Further instruction may be found in the Adobe's manual. Use a separate diskette for each filing. Submit the diskette in an envelope with the case name, case number, type and title of document, and the file name on the outside of the envelope. If you are unable to comply with this requirement, or requirement number 1, then 3. You must submit your documents on a diskette using one of the following formats: Word, Wordperfect, or DOS text (ASCII). If you are unable to comply with this requirement, or requirements 1 or 2, then 4. You must submit an affidavit of your inability to file in either of the above formats. You may then file conventionally on unstapled, unbound, single-sided paper. Include your affidavit with your filing. * DO NOT SUBMIT CLAIMS THROUGH THE COURT'S ELECTRONIC FILING SYSTEM AT THIS TIME. For technical assistance, call (212) 668-2870 ext. 3522, for procedural assistance call ext. 3920 and to schedule training, call ext. 3580, Monday -Friday, 8:30 a.m. - 5:00 p.m. EST. Dated: October 9, 1998 Cecelia G. Morris, Clerk of Court .gc7'//3 Hello