United States Bankruptcy Court 

District of New Hampshire

In re Derry & Webster, LLC Case No. 

 Debtor(s) Chapter 11

Derry & Webster, LLC'S DISCLOSURE STATEMENT, DATED OCTOBER 1, 2013

I. INTRODUCTION 

This is the disclosure statement (the "Disclosure Statement") in the chapter11 case of Derry & Webster, LLC (the 

"Debtor"). This Disclosure Statement contains information about the Debtor and describes the Derry & Webster, LLC’s 

Plan of Reorganization, Dated October 1, 2013 (the "Plan"). Your rights may be affected. You should read the Plan and 

this Disclosure Statement carefully and discuss them with your attorney. If you do not have an attorney, you may wish 

to consult one.

The proposed distributions under the Plan are discussed at pages 4-7 of this Disclosure Statement. The Plan calls 

for continuous adequate protection payments to the First Mortgage Secured Creditor in the amount of the net rents 

collected on a monthly basis. The second mortgage held by the same first mortgage creditor will receive a nominal 

adequate protection payment. Both the first and second mortgages will be settled in full at the end of the plan. General 

unsecured creditors are classified in Class 4, and will receive a distribution of 10% of their allowed claims, to be 

distributed from additional contributions of the owner. 

Purpose of This Document

This Disclosure Statement describes: 

The Debtor and significant events during the bankruptcy case, 

How the Plan proposes to treat claims or equity interests of the type you hold (i.e., what you will receive on your 

claim or equity interest if the plan is confirmed), 

Who can vote on or object to the Plan, 

What factors the Bankruptcy Court (the "Court") will consider when deciding whether to confirm the Plan, 

Why the Debtor believes the Plan is feasible, and how the treatment of your claim or equity interest under the 

Plan compares to what you would receive on your claim or equity interest in liquidation, and 

The effect of confirmation of the Plan. 

Be sure to read the Plan as well as the Disclosure Statement. This Disclosure Statement describes the Plan, but it 

is the Plan itself that will, if confirmed, establish your rights. 

II. BACKGROUND

A. Description and History of the Debtor's Business 

The Debtor is a Limited Liability Company. Since February 1, 2003, the Debtor has been in the business of 

developing and managing the realty located at 187 Webster St, Hudson, New Hampshire. The Debtor acquired the 

property because it was in the business of developing and managing real estate into commercial operations and residential 

subdivisions. This particular project was initiated on the basis of funds available from seller financing, and improvements 

were made through other sources controlled or owned by the members. Until this filing, the payments to the secured 

creditor were being made out of the proceeds of the rental of residential and commercial units within the subdivision. 

B. Insiders of the Debtor 

The members of the Debtor are Vatche Manoukian (90%) and Linda Haytayan, (10%) members, with Vatche 

Manoukian as the named managing member. Neither member has ever received any compensation from the Debtor. In 

fact, both members have contributed substantial additional capital to rehabilitate the subdivision improvements so that 

there would be an income produced from the property. Linda Haytayan is presently a chapter 11 debtor in case no. 13-

10697. 

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C. Management of the Debtor Before and During the Bankruptcy

During the five years prior to the date on which the bankruptcy petition was filed, the managing member in 

control of the Debtor (the "Manager") was Vatche Manoukian. He has 20+ years managing commercial and residential 

units as well as extensive experience in the construction and development of subdivisions, both commercial and 

residential. He is the managing member of 43 other entities that own or develop real estate. He has been the Managing 

member during the Debtor’s chapter 11 case. After the confirmation of the plan, he will continue to be the managing 

member of the Debtor. The responsibilities and compensation of the Managing Member is described in section III D of 

this Disclosure Statement. 

D. Events Leading to Chapter 11 Filing

This Debtor finds itself in chapter 11 again due to the legal impossibility of complying with the confirmed plan in 

case no. 10-12679, and residual impact of the drastic economic conditions lingering since the last economic depression. 

Debtor has accommodated those tenants who were able to pay something, and replaced those tenants who are not able to 

pay at all for an extended period. Prior to assented dismissal of chapter 11 case no. 12-12958, in which Debtor believed 

the creditor Bayview was in agreement with a short sale or forbearance plan, but at the same time moved forward with a 

foreclosure notice. 

E. Significant Events During the Bankruptcy Case

The Secured Creditor, Bayview Loan Servicing, LLC., had offered to accept a short sale at $680,000 if closed 

prior to the foreclosure date of October 3, 2013. Debtor has a buyer for $680,000 cash, but the buyer is unable to close on 

or before October 3, 2013 resulting in this filing. 

F. Projected Recovery of Avoidable Transfers 

The Debtor has completed its investigation with regard to pre-petition transactions. There were no payments or 

transfers by Debtor within 90 days of the bankruptcy filing to any third party. There were no payments or transfers by 

Debtor within 1 year of the bankruptcy filing to any insider or related party. If you received a payment or other transfer 

within 90 days of the bankruptcy, or other transfer avoidable under the Code, the Debtor may seek to avoid such transfer. 

G. Claims Objections

Except to the extent that a claim is already allowed pursuant to a final non-appealable order, the Debtor reserves 

the right to object to claims. Therefore, even if your claim is allowed for voting purposes, you may not be entitled to a 

distribution if an objection to your claim is later upheld. The procedures for resolving disputed claims are set forth in 

Article V of the Plan. 

H. Current and Historical Financial Conditions

Prior to and during the case, Debtor was unable to collect all rents due the economic circumstances of the tenants. 

Some of the commercial rents were temporarily reduced to allow those tenants to survive and regroup so that the full rents 

could be collected upon the effective date of the plan. The residential tenants had great difficulty paying the full rents. 

Reductions were allowed for those facing temporary issues. Replacement was the only option for those who faced 

permanent issues. An accident occurred in April 2013 that hampered the remittance process. The repairs have all been 

made and the property affected, the convenience store, is fully occupied. 

Debtor has been operating since 2003 as property manager of the realty located at 187 Webster Street, Hudson, 

NH. Currently, the property has multiple uses based upon it: A convenience store, a landscaping contractor business and 

related storage areas, 8 storage units & 3 residential units. A couple of the storage units are vacant. 

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III. SUMMARY OF THE PLAN OF REORGANIZATION AND TREATMENT OF CLAIMS AND EQUITY 

INTERESTS

A. What is the Purpose of the Plan of Reorganization?

As required by the Code, the Plan places claims and equity interests in various classes and describes the treatment 

each class will receive. The Plan also states whether each class of claims or equity interests is impaired or unimpaired. If 

the Plan is confirmed, your recovery will be limited to the amount provided by the Plan. 

B. Class 1 Claims – Administrative, Priority, nominal

Certain types of claims are automatically entitled to specific treatment under the Code. They are not considered 

impaired, and holders of such claims do not vote on the Plan. They may, however, object if, in their view, their treatment 

under the Plan does not comply with that required by the Code. As such, the Plan Proponent has not placed the following 

claims in any class: 

1. Administrative Expenses

Administrative expenses are costs or expenses of administering the Debtor's chapter 11 case which are allowed 

under § 507(a)(2) of the Code. Administrative expenses also include the value of any goods sold to the Debtor in the 

ordinary course of business and received within 20 days before the date of the bankruptcy petition. The Code requires 

that all administrative expenses be paid on the effective date of the Plan, unless a particular claimant agrees to a different 

treatment. 

The following chart lists the Debtor's estimated administrative expenses, and their proposed treatment under the 

Plan: 

Type Estimated

Amount Owed

Proposed Treatment

Expenses Arising in the Ordinary Course of 

Business After the Petition Date 

$0.00 Paid in full on the effective date of the Plan, or 

according to terms of obligation if later 

Super-priority for the costs to plan, apply for 

approval & market the condo units after the 

effective date of the Plan. 

$0.00 Paid after the effective date of the Plan, out of 

proceeds of sale of condo units in amount pro 

rata to the portion that the first mortgage 

creditor would be entitled to for each sale. 

Professional Fees, as approved by the Court. $10,000.00 Paid in full on the effective date of the Plan, or 

according to separate written agreement, or 

according to court order if such fees have not 

been approved by the Court on the effective 

date of the Plan 

Clerk's Office Fees $0.00 Paid in full on the effective date of the Plan 

Nominal claims (those not exceeding $500) $0.00 Paid in full on the effective date of the Plan or 

according to separate written agreement 

Office of the U.S. Trustee Fees $975.00 Paid in full on the effective date of the Plan 

TOTAL $10,975.00 

2. Priority Tax Claims

Priority tax claims are unsecured income, employment, and other taxes described by § 507(a)(8) of the Code. 

Unless the holder of such a § 507(a)(8) priority tax claim agrees otherwise, it must receive the present value of such claim, 

in regular installments paid over a period not exceeding 5 years from the order of relief. 

The following chart lists the Debtor's estimated § 507(a)(8) priority tax claims and their proposed treatment under 

the Plan: 

Description 

(name and type of tax) 

Estimated 

Amount

Date of

Assessment

Treatment 

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Owed

 Town of Hudson– Property taxes 

 

CURRENT 2013- 2nd half Paid by Debtor 

in the future. 

 

C. Classes of Claims and Equity Interests

The following are the classes set forth in the Plan, and the proposed treatment that they will receive under the 

Plan: 

1. Classes of Secured Claims

Allowed Secured Claims are claims secured by property of the Debtor's bankruptcy estate (or that are subject to 

setoff) to the extent allowed as secured claims under § 506 of the Code. If the value of the collateral or setoffs securing 

the creditor's claim is less than the amount of the creditor's allowed claim, the deficiency will be classified as a general 

unsecured claim. 

The following chart lists all classes containing Debtor's secured pre-petition claims and their proposed treatment 

under the Plan: 

Class # Description Insider

? 

(Yes or 

No) 

Impairment Treatment 

 2 Secure claim of: 

Name = Bayview Loan Servicing, LLC

 

Collateral Description = realty at 187 

Webster, Hudson NH

 

Allowed Secured Amount = 

$1,300,000

Priority of lien = 100% secured- 1st

position

 

Principal owed =$1,300,000

Pre-pet. arrearage =$0.00

Total claim =$1,300,000

No Yes 

Amortization: 

FMV: $680K 

% rate: 2% 

Period: 20 yrs 

Years 1 & 2 

will be interest 

only at 

$2,600/month 

Years 3-5 will 

be P&I at 

$3,440/month 

Monthly payment 

Yrs 1-2 % only 

Yrs 3-5 P&I 

Pmts Begin 

Pmts End 

Balloon pmts made at 

end of plan 

Interest rate % 

Amortization period 

Treatment of Lien 

Int portion of each 

payment 

= $2,600.00

= $3,440.00 

= 10/10/2013

= 10/1/2018

= Short sale to be 

completed before 

end of 5 yr plan. 

= 2.0% 

= 20 years 

= remains secure

= $2,600.00

Class # Description Impai

rment

Treatment 

3 Secure claim of: 

Name = Bayview Loan Servicing, LLC

 

Collateral Description = realty at 187 Webster, 

Hudson NH

 

Allowed Secured Amount = $150,000

Priority of lien = 2nd position- secured

 

Yes Monthly payment 

Balloon Pmts made at 

end of plan. 

Interest rate % 

Treatment of Lien 

= $100.00

= 0.00% 

= 2nd position 

“secured” 

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Class # Description Impai

rment

Treatment 

Principal owed = $150,000

Pre-pet. arrearage = $0.00 

Total secured claim = $150,000

2. Classes of Priority Secured Claims

Certain priority claims that are referred to in §§ 507(a)(1), (4), (5), (6), and (7) of the Code are required to be 

placed in classes. The Code requires that each holder of such a claim receive cash on the effective date of the Plan equal 

to the allowed amount of such claim. However, a class of holders of such claims may vote to accept different treatment. 

The following chart lists all classes containing claims under §§ 507(a)(1), (4), (5), (6), and (a)(7) of the Code and their 

proposed treatment under the Plan: NONE

3. Class of General Unsecured Claims

General unsecured claims are not secured by property of the estate and are not entitled to priority under § 507(a) 

of the Code. 

The following chart identifies the Plan's proposed treatment of Class 4, which contain general unsecured claims 

against the Debtor: 

Class # Description Impairment Treatment 

 

4 General Unsecured Class 

Maynard & Paquette $240,000 

Prunier & Prolman $5,000 

Saco Construction $10,000.00 

Town of Hudson sewer liens $1,200.00 

Total Claims in Class 4: $256,200 

Impaired Monthly amount 

To be paid monthly 

Interest included in payment 

estimated percent of claims 

paid via plan payments 

(total =$25,620) 

= $426.66 

= 0.00%

= 10%

4. Class of Equity Interest Holders

Equity interest holders are parties who hold an ownership interest (i.e., equity interest) in the Debtor. In a 

corporation, entities holding preferred or common stock are equity interest holders. In a partnership, equity interest 

holders include both general and limited partners. In a limited liability company ("LLC"), the equity interest holders are 

the members. Finally, with respect to an individual who is a debtor, the Debtor is the equity interest holder. 

The following chart sets forth the Plan's proposed treatment of the class of equity interest holders: 

Class # Description Impairment Treatment 

 5 Equity interest holders: 

Vatche Manoukian 90% 

Linda Haytayan 10% 

Impaired Equity holders will receive no compensation 

during the term of the plan. 

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D. Means of Implementing the Plan

1. Source of Payments

Payments and distributions under the Plan will be funded by the following: Beginning on October 10, 2013 and 

for the first two years of the plan, the debtor will pay $2,600.00 per month to the Secured Creditor, Bayview Loan 

Servicing, LLC for the first mortgage, and $100.00 per month for the second mortgage, from collected rents. During 

years 3-5 of the plan, the payment on the first mortgage shall be $3,440.00 per month to Bayview. All payments to the 

creditor will be made by the 10th of each month according to the schedule listed in the Plan. The property taxes will be 

paid by the debtor. Insurance & CAM will be paid by the Debtor from rents collected. 

2. Post-confirmation Management

The Post-Confirmation Managers of the Debtor, and their compensation, shall be as follows: 

Name Affiliations Insider (yes or no)? Position Compensation 

 Vatche Manoukian Managing Member Yes Managing Member None 

 Linda Haytayan Member Yes Member None

E. Risk Factors

The proposed Plan has the following risks: 

Particularly in today’s economic depression, the success of the plan is dependent on rental payments from tenants 

and significant rebound in the sales of existing units. 

Opponents of the Plan are very pessimistic about the future prospects of the real estate market. Debtor shares 

their pessimism, but will be making these mortgages productive until the market rebounds and other options are available. 

F. Executory Contracts and Unexpired Leases

All executory contracts and unexpired leases that are not listed in the Plan at Article VI will be rejected under the 

Plan. Consult your adviser or attorney for more specific information about particular contracts or leases. 

If you object to the rejection of your contract or lease, you must file and serve your objection to the Plan within 

the deadline for objecting to the confirmation of the Plan. 

G. Tax Consequences of Plan

Creditors and Equity Interest Holders Concerned with How the Plan May Affect Their Tax Liability Should 

Consult with Their Own Accountants, Attorneys, And/Or Advisors.

The Debtor has no reasonable way to predict any anticipated tax consequences of the Plan to the Debtor, or any creditors 

pertaining to or of any discharge, or the general tax consequences of receipt of plan consideration after confirmation. 

IV. CONFIRMATION REQUIREMENTS AND PROCEDURES

To be confirmable, the Plan must meet the requirements listed in §§ 1129(a) or (b) of the Code. These include the 

requirements that: the Plan must be proposed in good faith; at least one impaired class of claims must accept the plan, 

without counting votes of insiders; the Plan must distribute to each creditor and equity interest holder at least as much as 

the creditor or equity interest holder would receive in a chapter 7 liquidation case, unless the creditor or equity interest 

holder votes to accept the Plan; and the Plan must be feasible. These requirements are not the only requirements listed in 

§ 1129, and they are not the only requirements for confirmation. 

A. Who May Vote or Object

Any party in interest may object to the confirmation of the Plan if the party believes that the requirements for 

confirmation are not met. 

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Many parties in interest, however, are not entitled to vote to accept or reject the Plan. A creditor or equity interest 

holder has a right to vote for or against the Plan only if that creditor or equity interest holder has a claim or equity interest 

that is both (1) allowed or allowed for voting purposes and (2) impaired. 

In this case, the Plan Proponent believes that classes 2, 3, 4 & 5 are impaired and that holders of claims in each 

of these classes are therefore entitled to vote to accept or reject the Plan. The Plan Proponent believes that class 1 is 

unimpaired and that holders of claims in class 1, therefore, do not have the right to vote to accept or reject the Plan. 

1. What Is an Allowed Claim or an Allowed Equity Interest?

Only a creditor or equity interest holder with an allowed claim or an allowed equity interest has the right to vote 

on the Plan. Generally, a claim or equity interest is allowed if either (1) the Debtor has scheduled the claim on the 

Debtor's schedules, unless the claim has been scheduled as disputed, contingent, or unliquidated, or (2) the creditor has 

filed a proof of claim or equity interest, unless an objection has been filed to such proof of claim or equity interest. When 

a claim or equity interest is not allowed, the creditor or equity interest holder holding the claim or equity interest cannot 

vote unless the Court, after notice and hearing, either overrules the objection or allows the claim or equity interest for 

voting purposes pursuant to Rule 3018(a) of the Federal Rules of Bankruptcy Procedure. 

The deadline for filing a proof of claim in this case has passed. 

2. What Is an Impaired Claim or Impaired Equity Interest?

As noted above, the holder of an allowed claim or equity interest has the right to vote only if it is in a class that is 

impaired under the Plan. As provided in § 1124 of the Code, a class is considered impaired if the Plan alters the legal, 

equitable, or contractual rights of the members of that class. 

3. Who is Not Entitled to Vote

The holders of the following five types of claims and equity interests are not entitled to vote: 

holders of claims and equity interests that have been disallowed by an order of the Court; 

holders of other claims or equity interests that are not "allowed claims" or "allowed equity interests" (as 

discussed above), unless they have been "allowed" for voting purposes. 

holders of claims or equity interests in unimpaired classes; 

holders of claims entitled to priority pursuant to §§ 507(a)(2), (a)(3), and (a)(8) of the Code; and 

holders of claims or equity interests in classes that do not receive or retain any value under the Plan; 

administrative expenses. 

Even If You Are Not Entitled to Vote on the Plan, You Have a Right to Object to the Confirmation of the Plan and to 

the Adequacy of the Disclosure Statement.

4. Who Can Vote in More Than One Class

A creditor whose claim has been allowed in part as a secured claim and in part as an unsecured claim, or who 

otherwise hold claims in multiple classes, is entitled to accept or reject a Plan in each capacity, and should cast one ballot 

for each claim. 

B. Votes Necessary to Confirm the Plan

If impaired classes exist, the Court cannot confirm the Plan unless (1) at least one impaired class of creditors has 

accepted the Plan without counting the votes of any insiders within that class, and (2) all impaired classes have voted to 

accept the Plan, unless the Plan is eligible to be confirmed by "cram down" on non-accepting classes, as discussed later in 

Section B.2. 

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1. Votes Necessary for a Class to Accept the Plan

A class of claims accepts the Plan if both of the following occur: (1) the holders of more than one-half (1/2) of the 

allowed claims in the class, who vote, cast their votes to accept the Plan, and (2) the holders of at least two-thirds (2/3) in

dollar amount of the allowed claims in the class, who vote, cast their votes to accept the Plan. 

A class of equity interests accepts the Plan if the holders of at least two-thirds (2/3) in amount of the allowed 

equity interests in the class, who vote, cast their votes to accept the Plan. 

2. Treatment of Nonaccepting Classes

Even if one or more impaired classes reject the Plan, the Court may nonetheless confirm the Plan if the 

nonaccepting classes are treated in the manner prescribed by § 1129(b) of the Code. A plan that binds nonaccepting 

classes is commonly referred to as a "cram down" plan. The Code allows the Plan to bind nonaccepting classes of claims 

or equity interests if it meets all the requirements for consensual confirmation except the voting requirements of § 

1129(a)(8) of the Code, does not "discriminate unfairly," and is "fair and equitable" toward each impaired class that has 

not voted to accept the Plan. 

You should consult your own attorney if a "cramdown" confirmation will affect your claim or equity interest, 

as the variations on this general rule are numerous and complex.

C. Liquidation Analysis

To confirm the Plan, the Court must find that all creditors and equity interest holders who do not accept the Plan 

will receive at least as much under the Plan as such claim and equity interest holders would receive in a chapter 7 

liquidation. A liquidation analysis is attached to this Disclosure Statement as Exhibit D. 

D. Feasibility

The Court must find that confirmation of the Plan is not likely to be followed by the liquidation, or the need for 

further financial reorganization, of the Debtor or any successor to the Debtor, unless such liquidation or reorganization is 

proposed in the Plan. 

1. Ability to Initially Fund Plan

The Debtor will have enough cash on hand on the effective date of the Plan to pay all the claims and expenses that 

are entitled to be paid on that date, in particular Class 1. This will come from additional member contributions. Presently, 

Debtor has the sum of $2,600 on hand, and will make the plan payments due to classes 2, 3 & 4 on the 10th of October 

2013, according to the terms of the plan and as approved by the Court. The same will be done for each month thereafter 

for a total of 60 months. 

 2. Ability to Make Future Plan Payments And Operate Without Further Reorganization

The Plan Proponent must also show that it will have enough cash over the life of the Plan to make the required 

Plan payments. 

The Plan Proponent has provided projected financial information. Those projections are listed in Exhibit Rental 

Income & Expense Projections. 

The Plan Proponent's financial projections show that the rents will be sufficient to pay the Secured Creditor 

interest only for the term of the plan, with a payoff via short sale at or before the end of the plan. 

You Should Consult with Your Accountant or other Financial Advisor If You Have Any Questions Pertaining 

to These Projections.

V. EFFECT OF CONFIRMATION OF PLAN

A. DISCHARGE OF DEBTOR 

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Discharge. On the effective date of the Plan, the Debtor shall be discharged from any debt that arose before 

confirmation of the Plan, subject to the occurrence of the effective date, to the extent specified in § 1141(d)(1)(A) of the 

Code, except that the Debtor shall not be discharged of any debt (i) imposed by the Plan, (ii) of a kind specified in § 

1141(d)(6)(A) if a timely complaint was filed in accordance with Rule 4007(c) of the Federal Rules of Bankruptcy 

Procedure, or (iii) of a kind specified in § 1141(d)(6)(B). After the effective date of the Plan your claims against the 

Debtor will be limited to the debts described in clauses (i) through (iii) of the preceding sentence. 

B. Modification of Plan

The Plan Proponent may modify the Plan at any time before confirmation of the Plan. However, the Court may 

require a new disclosure statement and/or revoting on the Plan. 

Upon request of the Debtor, the United States trustee, or the holder of an allowed unsecured claim, the Plan may 

be modified at any time after confirmation of the Plan but before the completion of payments under the Plan, to (1) 

increase or reduce the amount of payments under the Plan on claims of a particular class, (2) extend or reduce the time 

period for such payments, or (3) alter the amount of distribution to a creditor whose claim is provided for by the Plan to 

the extent necessary to take account of any payment of the claim made other than under the Plan. 

C. Final Decree

Once the estate has been fully administered, as provided in Rule 3022 of the Federal Rules of Bankruptcy 

Procedure, the Plan Proponent, or such other party as the Court shall designate in the Plan Confirmation Order, shall file a 

motion with the Court to obtain a final decree to close the case. Alternatively, the Court may enter such a final decree on 

its own motion. 

VI. OTHER PLAN PROVISIONS

None 

/s/ Vatche Manoukian

Vatche Manoukian, Managing Member of 

Derry & Webster, LLC

Plan Proponent 

/s/ Robert L. O'Brien

Robert L. O'Brien 15358

Attorney at Law

P.O. Box 357 

New Boston NH 03070 

603-459-9965 

603-250-0822 Fax 

robjd@mail2firm.com

Attorney for the Plan Proponent 

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EXHIBITS

Exhibit A Appraisal 

Exhibit B – Cash Report 

Exhibit C – Rent Rolls 

Exhibit D – Liquidation Summary 

Exhibit E - Projections 

Exhibit F – Ballots cast by creditors of the General Unsecured Class 

Exhibit G – Ballot Form 

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