Groeb Farms, Inc., a honey processor and producer of industrial sweeteners headquartered in Onsted, MI, filed a Chapter 11 bankruptcy petition on October 1, 2013. The U.S. Department of Justice accused Groeb Farms of evading anti-dumping duties on honey imported from China. Although Groeb Farms was able to settle these allegations through payment of a $2 million fine and other penalties, related class action lawsuits along with more than $12 million in losses in 2011 and 2012 forced Groeb Farms to seek bankruptcy court protection. Before the bankruptcy filing, Groeb Farms agreed to a purchase agreement with Honey Financing Company, an affiliate of Peak Rock Capital. Groeb Farms also reached pre-filing agreements with its secured lenders (which included the purchase of senior secured debt by Honey Financing) and with counsel for the class action plaintiffs. On the first day of the bankruptcy case, in addition to all the typical first day motions, Groeb Farms filed its Disclosure Statement attaching a proposed Plan of Reorganization. Under the Plan, Honey Financing would receive 100% of the equity of Groeb Farms by a partial conversion of debt to equity. The Plan proposes paying unsecured trade creditors forty percent recovery of their unsecured claims over time, but only if Groeb Farms and the creditor enter into a continuing trade agreement subject to Groeb Farms’ terms. The Plan proposes establishing a trust to pursue lawsuits with initial seed money of $50,000. All general unsecured creditors, and any trade creditor that does not receive a continuing trade agreement, would share the net proceeds, if any, from the trust. Groeb Farms and Peak Rock Capital are seeking expedited approval of the sale and related agreements through confirmation of the Plan by the Bankruptcy Court — they have requested that the confirmation hearing be held before the end of 2013. The Bankruptcy Court has accommodated the debtor’s request for expedited proceedings, scheduling expedited hearings, and entering a November 4, 2013 bar date for all proofs of claims and motions for payment of pre-petition administrative expense claims.