Case 4:23-cv-04033-HSG Document 78 Filed 01/17/24 Page 1 of 13
`
`KATHERINE CONNOLLY (SBN 313640)
`katie.connolly@nortonrosefulbright.com
`NORTON ROSE FULBRIGHT US LLP
`555 California Street, Suite 3300
`San Francisco, CA 94140
`Tel. (628) 231-6800
`DANIEL MCNEEL LANE, JR. (Pro Hac Vice)
`neel.lane@nortonrosefulbright.com
`NORTON ROSE FULBRIGHT US LLP
`111 W. Houston Street, Suite 1800
`San Antonio, TX 78205
`Tel. (210) 224-5575
`JEANNIE NGUYEN (Pro Hac Vice)
`jeannie.nguyen@nortonrosefulbright.com
`NORTON ROSE FULBRIGHT US LLP
`1301 McKinney, Suite 5100
`Houston, Texas 77010-3095
`Tel. (713) 651-5151
`Attorneys for Plaintiff
`HISCOX SYNDICATES LIMITED
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`
`Case No. 4:23-cv-04033-HSG
`
`AMENDED STIPULATION RESOLVING
`INTERPLEADER ACTION; ORDER
`
`Complaint Filed:
`First Am. Compl.
`
`08/09/2023
`08/10/2023
`
`HISCOX SYNDICATES LIMITED,
`a Private Limited Company formed in
`England,
`
`Plaintiff,
`
`vs.
`SAMUEL BANKMAN-FRIED, NISHAD
`SINGH, RAMNIK ARORA, CLAIRE
`WATANABE, HOWARD ANDREW
`FISHER, AMY WU, ZIXIAO (GARY)
`WANG, RYAN SALAME, CAN SUN,
`CONSTANCE ZHE WANG, LUK WAI
`(JEN) CHAN, NATALIE TIEN, ZANE
`TACKETT, ZHONGYUAN (DAVID) MA,
`DANIEL FRIEDBERG, ROBIN MATZKE,
`PATRICK GRUHN, ROSS RHEINGANS-
`YOO, NICHOLAS BECKSTEAD, and
`JONATHAN CHEESMAN,
`Defendants.
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`DOCUMENT PREPARED
`ON RECYCLED PAPER
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`Case 4:23-cv-04033-HSG Document 78 Filed 01/17/24 Page 2 of 13
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`Pursuant to Rule 7-1 of the Civil Local Rules of the Unites States District Court, Northern
`District of California, Plaintiff Hiscox Syndicates Limited (“Plaintiff” or “Hiscox”) and
`Defendants Samuel Bankman-Fried, Nishad Singh, Ramnik Arora, Claire Watanabe, Amy Wu,
`Zixiao (Gary) Wang, Ryan Salame, Can Sun, Constance Zhe Wang, Luk Wai (Jen) Chan, Natalie
`Tien, Zane Tackett, Daniel Friedberg, Robin Matzke, Patrick Gruhn, Ross Rheingans-Yoo,
`Nicholas Beckstead, and Jonathan Cheesman (collectively the “Defendants”, together the
`“Parties”) 1 hereby stipulate and request that the Court enter this amended stipulation, which
`incorporates and supplements the Parties’ Stipulation Resolving Interpleader Action filed on
`December 20, 2023 (ECF No. 67), and entered by the Court on December 21, 2023 (ECF No. 72)
`(the “Original Stipulated Order”), with respect to interest earned on the $5,000,000.00 limits of
`the Hiscox insurance policy that is the subject of this interpleader action, Excess Insurance Policy
`No. B0146ERINT2201008 (the “Hiscox Policy”), deposited into the Registry of the Court
`(“Interpleader Funds”) and additional information required by the Court to disburse payment
`pursuant to the distribution plan set forth in the Original Stipulated Order.
`WHEREAS Plaintiff filed this interpleader action on August 9, 2023 (ECF No. 1);
`WHEREAS Plaintiff filed an amended complaint (ECF No. 7) on August 10, 2023,
`against Defendants, who were the known individual insureds with a potential interest in the
`proceeds of the Hiscox Policy as of the time of filing;
`WHEREAS the Hiscox Policy is the third-layer excess liability policy in Paper Bird Inc.’s
`$20 million tower of directors and officers liability insurance, and provides a $5 million limit of
`liability in excess of $15 million in aggregate limits of underlying insurance comprising of a
`primary policy issued by Certain Underwriters at Lloyd’s, London, a first-layer excess policy
`issued by QBE Insurance Corporation (“QBE”), and a second-layer excess policy issued by
`Continental Casualty Company (“CNA”), each with limits of $5 million;
`WHEREAS QBE exhausted its policy limits in partial payment of defense costs incurred
`through April 2023 and CNA subsequently initiated mediation to attempt a global resolution of
`
`
`1The Parties to this stipulation do not include Defendants Howard Andrew Fisher and Defendant
`Zhongyuan (David) Ma, who have been dismissed from this action.
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`AMENDED STIPULATION RESOLVING INTERPLEADER ACTION
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`CNA’s and Hiscox’s layers;
`WHEREAS the amount of defense costs submitted for payment by Defendants and
`determined to be covered at the time of mediation exceeded the combined limits of CNA’s and
`Hiscox’s layers;
`WHEREAS Hiscox maintains that it did not and does not take a position as to an
`appropriate allocation among insureds because Hiscox has stated that it disclaims any interest in
`the proceeds;
`WHEREAS, following two formal mediation sessions and substantial efforts by the
`mediator and mediation participants over the course of several weeks, a tentative global
`resolution was reached (see Declaration of David M. Murphy, ECF No. 67-1) and an agreement
`regarding the proposed resolution of this interpleader action was fully executed on November 22,
`2023 (the “Settlement Agreement”);
`WHEREAS, as noted in the mediator’s declaration, the mediation process was extremely
`complex and hard fought, and in the mediator’s professional opinion that the proposed
`distribution plan is “the best obtainable consensual resolution among the Participating Claimants,
`taking into consideration all of the costs, uncertainties, risks, and delay of further litigation” (see
`Declaration of David M. Murphy, ECF No. 67-1);
`WHEREAS on November 22, 2023, Hiscox filed a Stipulation and Proposed Order for
`Stay and Deposit of Interpleader Funds (ECF No. 59);
`WHEREAS on November 28, 2023, the Court entered an Order Directing Clerk to Accept
`Deposit of Interpleader Funds (ECF No. 61);
`WHEREAS the Interpleader Funds have been deposited into the Registry of the Court (see
`ECF No. 70);
`WHEREAS on November 30, 2023, Hiscox filed an Administrative Motion for Order
`Resolving Interpleader Action (ECF No. 62) (the “Administrative Motion”), seeking entry of a
`Proposed Approval Order to resolve this action pursuant to the Parties’ agreement;
`WHEREAS on December 5, 2023, the Court issued an Order stating that “[t]he Court
`does not take issue with the mediation outcome or the substance of the proposed order, but is of
`
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`DOCUMENT PREPARED
`ON RECYCLED PAPER
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`138604036.2
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`the view that clarity would be best served by presenting the agreement differently” (ECF No. 64);
`WHEREAS the December 5, 2023, Order terminated the Administrative Motion and
`directed Hiscox to file (1) “a stipulation agreeing to the proposed resolution of the interpleader
`action as to the settling parties identified in the Proposed Approval Order” and (2) “an
`administrative motion seeking resolution of the interpleader action as to Defendant David Ma,
`who appears to be the only Defendant from whom a stipulation cannot reasonably be obtained”;
`WHEREAS pursuant to the December 5, 2023, Order, the Parties entered into a
`stipulation which (1) sets forth the agreed-upon distribution of the Interpleader Funds under the
`Settlement Agreement, and (2) reserves a specific dollar amount of the Interpleader Funds and
`sets forth a procedure for disbursement to those persons potentially insured under the Hiscox
`Policy who were unable to participate in the mediation process;
`WHEREAS on December 20, 2023, pursuant to the December 5, 2023, Order, Hiscox
`filed the Parties’ Stipulation Resolving Interpleader Action (ECF No. 67) and the Administrative
`Motion Resolving Interpleader Action as to Zhongyuan (David) Ma (ECF No. 69);
`WHEREAS on December 21, 2023, the Court entered the Original Stipulated Order (ECF
`No. 72), ordering disbursement of the Interpleader Funds and granting Hiscox’s request for
`interpleader relief in connection with the Hiscox Policy, and a separate order (ECF No. 74)
`granting Plaintiff’s Administrative Motion Resolving Interpleader Action as to Defendant
`Zhongyuan (David) Ma and directing the Clerk to close this case;
`WHEREAS, subsequent to the Court’s entry of the orders on December 21, 2023, the
`Parties received notice that the Court needed additional information to disburse payment as
`contemplated in the Original Stipulated Order;
`WHEREAS the Parties enter into this amended stipulation to provide additional
`information so that the Court may disburse payments as contemplated in the Original Stipulated
`Order; and
`WHEREAS Local Rule 7-1 provides that parties may present a request to the Court for an
`order by stipulation pursuant to Local Rule 7-12;
`WHEREFORE the Parties stipulate and request that this Court enter the amended
`
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`DOCUMENT PREPARED
`ON RECYCLED PAPER
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`Case 4:23-cv-04033-HSG Document 78 Filed 01/17/24 Page 5 of 13
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`stipulation below.
`Disbursements to the Pro Rata Claimants
`I.
`1.
`The sum of $4,375,000.00 of the Interpleader Funds deposited into the Registry of
`the Court shall be disbursed for reimbursement of defense costs incurred by each the following
`individual claimants (“Pro Rata Claimants”) in the respective principal amounts and to the payees
`set forth in the amended payment schedule, filed under seal as Exhibit A to this Amended
`Stipulation Resolving Interpleader Action (the “Amended Payment Schedule”):
`a. Samuel Bankman-Fried
`b. Nishad Singh
`c. Zixiao (Gary) Wang
`d. Amy Wu
`e. Ramnik Arora
`f. Claire Watanabe
`g. Ryan Salame
`h. Can Sun
`i. Constance Zhe Wang
`j. Luk Wai (Jen) Chan
`k. Natalie Tien
`l. Zane Tackett
`m. Tristan Yver*
`n. Armani Ferrante*
`o. Claire Zhang*
`p. Jonathan Cheesman
`q. Patrick Gruhn and Robin Matzke
`r. Nicholas Beckstead
`
`
`* Tristan Yver, Armani Ferrante, and Claire Zhang were not named as defendants in the First
`Amended Complaint for Interpleader.
`138604036.2
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`II.
`
`Disbursement to Daniel Friedberg
`2.
`The principal amount of $225,000.00 of the Interpleader Funds deposited into the
`Registry of the Court shall be disbursed to Daniel Friedberg.
`Interest on Disbursements to the Pro Rata Claimants and Daniel Friedberg
`III.
`3.
`Interest earned on the principal amounts set out in the Amended Payment Schedule
`for the Pro Rata Claimants and Daniel Friedberg (totaling $4,600,000.00) shall be distributed
`from the Registry of the Court in accordance with the “Percentage for One-Time Disbursement of
`Interest” to the payees set forth in the Amended Payment Schedule, with the percentages applied
`to the amount of interest earned as of the date of the distribution from the Registry of the Court.
`The WBR Set Aside
`IV.
`4.
`The principal amount of $200,000.00 (the “WBR Set Aside”) shall be reserved for
`reimbursement of defense costs incurred by Defendants Claire Watanabe, Nicholas Beckstead,
`and Ross Rheingans-Yoo (“WBR Claimants”), each of whom may seek up to one-third, or
`$66,666.67 of the WBR Set Aside and interest earned on those respective principal amounts.
`5.
`The WBR Claimants shall make requests for distribution of the WBR Set Aside by
`letter to the Court filed on the docket and attaching summary invoices for the Court’s review.
`Upon consideration of any request by any of the WBR Claimants, together with any additional
`information requested by the Court (including in camera submission of complete invoices) to
`establish that the claimant is entitled to the requested payment from the Interpleader Funds, the
`Court shall order that such amounts be paid from the Registry of the Court.
`6.
`Remaining amounts of the WBR Set Aside that have not been disbursed to the
`WBR Claimants as of December 21, 2024, together with any interest earned on those principal
`amounts, shall be distributed from the Registry of the Court to the payees for the Pro Rata
`Claimants on a pro rata basis in accordance with the “Percentage for Disbursement of Remaining
`Amounts” set forth in the Amended Payment Schedule.
`The Future Claimant Set Aside
`V.
`7.
`The principal amount of $200,000.00 (the “Future Claimant Set Aside”) shall be
`reserved for reimbursement of defense costs incurred by the WBR Claimants, each of whom may
`
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`Case 4:23-cv-04033-HSG Document 78 Filed 01/17/24 Page 7 of 13
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`seek up to one-sixth, or $33,333.33 of the Future Claimant Set Aside and interest earned on those
`respective principal amounts, and any other claimants who did not participate in mediation
`(“Future Claimants”). Amounts of the Future Claimant Set Aside and interest earned on those
`respective principal amounts that are not paid to the WBR Claimants shall be available to the
`Future Claimants, including Zhongyuan (David) Ma.
`8.
`The WBR Claimants and Future Claimants shall make requests for distribution of
`the Future Claimant Set Aside by letter to the Court filed on the docket and attaching summary
`invoices for the Court’s review. Upon consideration of any request by any of the WBR Claimants
`or Future Claimants, together with any additional information requested by the Court (including
`in camera submission of complete invoices) to establish that the claimant is entitled to the
`requested payment from the Interpleader Funds, the Court shall order that such amounts be paid
`from the Registry of the Court.
`9.
`Remaining amounts of the Future Claimant Set Aside that have not been disbursed
`to the WBR Claimants and Future Claimants as of December 21, 2024, together with any interest
`earned on those principal amounts, shall be distributed from the Registry of the Court to the
`payees for the Pro Rata Claimants on a pro rata basis in accordance with the “Percentage for
`Disbursement of Remaining Amounts” set forth in the Amended Payment Schedule.
`Interpleader Relief Under 28 U.S.C. § 1335 and Federal Rule of Civil Procedure 22
`VI.
`10.
`Plaintiff, a disinterested stakeholder, is discharged from further liability in
`connection with the limits of the Hiscox Policy.
`11.
`Plaintiff is dismissed with prejudice from this interpleader action.
`12.
`No further litigation shall be brought against Hiscox in connection with coverage
`under the Hiscox Policy.
`13.
`All claims related to the Hiscox Policy shall be litigated in this interpleader action.
`VII. Further Amendments to the Amended Payment Schedule and Distribution Plan
`14.
`Following entry of this amended stipulation, further amendments to the Amended
`Payment Schedule and the distribution plan set forth above may be requested by a supplemental
`
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`stipulation of the directly affected parties, including the WBR Claimants, Future Claimants, and
`Pro Rata Claimants, without further input from dismissed parties.
`
`Dated: January 16, 2024
`
`NORTON ROSE FULBRIGHT US LLP
`
`By:
`/s/ Daniel McNeel Lane, Jr.
`Daniel McNeel Lane, Jr.
`
`Attorney for Plaintiff
`HISCOX SYNDICATES LIMITED
`
`
`
`Dated: January 16, 2024
`
`FARELLA BRAUN + MARTEL, LLP
`
`By:
`/s/Shanti Eagle
`Shanti Eagle
`
`Attorney for Defendant
`RAMNIK ARORA
`
`COHEN & GRESSER LLP
`
`By:
`
`
`/s/ Benjamin Zhu
`Douglas J. Pepe
`Benjamin Zhu
`Attorneys for Defendant
`SAMUEL BANKMAN-FRIED
`
`COBLENTZ PATCH DUFFY & BASS LLP
`By:
`/s/ Benjamin C. Pulliam
`
`Benjamin C. Pulliam
`Franklin Cordell
`Attorneys for Defendant
`DANIEL FRIEDBERG
`
`
`Dated: January 16, 2024
`
`
`Dated: January 16, 2024
`
`
`
`
`Dated: January 16, 2024
`
`GOETZ FITZPATRICK LLP
`
`By:
`/s/ Scott D. Simon
`Scott D. Simon
`
`Attorney for Defendant
`ROSS RHEINGANS-YOO
`
`
`
`
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`Dated: January 16, 2024
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`JASSY VICK CAROLAN LLP
`
`By:
`/s/ William T. Um
`William T. Um
`
`Attorney for Defendant
`NISHAD SINGH
`
`
`
`Dated: January 16, 2024
`
`BAKER & MCKENZIE LLP
`
`By:
`/s/ Ronald L. Ohren
`Ronald L. Ohren
`
`Attorney for Defendant
`CLAIRE WATANABE
`
`STEPTOE & JOHNSON LLP
`
`By:
`/s/ Jennifer Karpinski (Singh)
`Jennifer Karpinski (Singh)
`
`Attorney for Defendants
`CAN SUN, CONSTANCE ZHE WANG, LUK
`WAI (JEN) CHAN, NATALIE TIEN, and ZANE
`TACKETT
`
`
`
`Dated: January 16, 2024
`
`
`
`Dated: January 16, 2024
`
`THE DALEY LAW FIRM, LLC
`
`By:
`
`
`/s/ Samantha Neal
`Darrell M. Daley
`Samantha Neal
`Attorney for Defendants
`PATRICK GRUHN and ROBIN MATZKE
`
`CLARK SMITH VILLAZOR LLP
`
`By:
`
`
`/s/ Rodney Villazor
`Rodney Villazor
` (CA Bar No. 310212)
`Attorney for Defendant
`JONATHAN CHEESMAN
`
`
`Dated: January 16, 2024
`
`
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`Case 4:23-cv-04033-HSG Document 78 Filed 01/17/24 Page 10 of 13
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`Dated: January 16, 2024
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`KELLER BENVENUTTI KIM LLP
`
`By:
`
`/s/ Dara L. Silveira
`Dara L. Silveira
`Jane Kim
`Attorneys for Defendant
`NICHOLAS BECKSTEAD
`
`Dated: January 16, 2024
`
`MAYER BROWN LLP
`
`By:
`
`/s/ Andrew J. Demko
`Andrew J. Demko
`Attorney for Defendant
`RYAN SALAME
`
`Dated: January 16, 2024
`
`COHEN ZIFFER FRENCHMAN &
`MCKENNA LLP
`
`By:
`
`/s/ John R. Hazelwood
`John R. Hazelwood
`(CA Bar No. 337988)
`Attorney for Defendant
`ZIXIAO (GARY) WANG
`
`Dated: January 16, 2024
`
`K&L GATES LLP
`
`By:
`
`/s/ Jason N. Haycock
`Jason N. Haycock
`(CA Bar: 278983)
`Jonathan Theonugraha
`(CA Bar: 306812)
`Steven P. Wright
`(pro hac vice to be filed)
`Attorneys for Defendant
`AMY WU
`
`PURSUANT TO STIPULATION, IT IS SO ORDERED ON THE 17th DAY OF
`
`JANUARY 2024
`
`________________________________________
`HON. HAYWOOD S. GILLIAM, JR.
`
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`Case 4:23-cv-04033-HSG Document 78 Filed 01/17/24 Page 11 of 13
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`FILER’S ATTESTATION
`Pursuant to Civil LR 5.1(i)(3), the undersigned hereby attests that concurrence in the filing
`of the foregoing AMENDED STIPULATION RESOLVING INTERPLEADER ACTION has
`been obtained from counsel for Defendants Samuel Bankman-Fried, Nishad Singh, Claire
`Watanabe, Ramnik Arora, Daniel Friedberg, Ross Rheingans-Yoo, Can Sun, Constance Zhe
`Wang, Luk Wai (Jen) Chan, Natalie Tien, Zane Tackett, Patrick Gruhn, Robin Matzke, Jonathan
`Cheesman, Nicholas Beckstead, Ryan Salame, Zixiao (Gary) Wang and Amy Wu and is
`electronically signed with the express permission of Defendants’ counsel.
`
`Dated: January 16, 2024
`
`NORTON ROSE FULBRIGHT US LLP
`
`By:
`
`/s/ Daniel McNeel Lane, Jr.
`Daniel McNeel Lane, Jr.
`
`Attorney for Plaintiff
`HISCOX SYNDICATES LIMITED
`
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`DOCUMENT PREPARED
`ON RECYCLED PAPER
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`138604036.2
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`Case No. 4:23-cv-04033-HSG
`- 11 -
`AMENDED STIPULATION RESOLVING INTERPLEADER ACTION
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`Case 4:23-cv-04033-HSG Document 78 Filed 01/17/24 Page 12 of 13
`Case 4:23-cv-04033-HSG Document 78 Filed 01/17/24 Page 12 of 13
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`EXHIBIT A
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`EXHIBIT A
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`Case 4:23-cv-04033-HSG Document 78 Filed 01/17/24 Page 13 of 13
`Case 4:23-cv-04033-HSG Document 78 Filed 01/17/24 Page 13 of 13
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`EXHIBIT FILED UNDER SEAL
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`EXHIBIT FILED UNDER SEAL
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