Clarification to Fact Pattern

FACT PATTERN CLARIFICATION REQUEST 1:
Is Silverman Sach’s argument that the federal bankruptcy court’s substantive consolidation power exceeds the court’s equity powers waived because it was not raised before the United States Court of Appeals for the Thirteenth Circuit?

FACT PATTERN CLARIFICATION 1:
As footnote 6 of the Fact Pattern indicates, Silverman did not raise that argument below.  While competitors are free to argue it if they wish, it may affect the scores they receive if the judges are not convinced that the argument is appropriate.  Competitors should have at least some familiarity with that issue so that they will be prepared to answer questions that may be raised by the judges in the oral rounds.

FACT PATTERN CLARIFICATION REQUEST 2:
On page 8 of the fact pattern, line five of the first full paragraph states: ". . . forced Silverman to pay STCM $5,940.000 based on . . ."  My question is whether the number should be $5,940,000 (or, five million nine hundred forty thousand dollars) instead of $5,940.000 (or, five thousand nine hundred and forty dollars and zero cents).

FACT PATTERN CLARIFICATION 2:
There is a typo. The period should be a comma and the correct amount is five million nine hundred forty thousand dollars.

FACT PATTERN CLARIFICATION REQUEST #3
I believe there is a discrepancy in the fact pattern near the top of page 7. The facts have the Bond value decreasing 79% (from $588.50 to $121.00, and more specifically 79.44% decrease). This would be a decrease of $28,050,000 (from $35,310,000 to $7,260,000). Add LIBOR of 2.82% of $33,000,000 (930,600) yields a total payment from STCM of $28,980,600, not $29,310,600 as the fact pattern states. If LIBOR were 3.82% (not 2.82% as the fact pattern states), it would be a 79.44% decrease ($121 Bond value) of $28,050,000 plus $1,260,600 LIBOR (3.82% of $33,000,000) payment yielding $29,310,600 - the number the fact pattern states.

That was a long-winded way of saying that if LIBOR on Feb 1, 2008 was 3.82% instead of 2.82%, the fact pattern would be consistent.

FACT PATTERN CLARIFICATION #3
You are correct.  The fact pattern should list LIBOR as 3.82, and not as 2.82, on the 8th line of page 7.  The dollar amounts remain unchanged.  This change will be made on the copy sent to judges and brief graders.