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IMO Liquidation of Indemnity Insurance Corporation, RRG

Citation: Not availableDocket: 185, 2022

Court: Supreme Court of Delaware; July 28, 2022; Delaware; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

The Delaware Court of Chancery appointed the Delaware Insurance Commissioner as the Receiver for Indemnity Insurance Corporation, RRG, as part of a liquidation process initiated on April 10, 2014. The Receiver's role was to manage claims and report on progress, leading to the Court's approval of the claim final determination and service plans by August 17, 2020. Subsequently, Jeffrey Cohen, the founder of IIC, objected to the Receiver’s determinations and sought to file a complaint, which the Court denied on April 14, 2022, as an improper attempt to initiate independent proceedings. Cohen's subsequent appeal was challenged for untimeliness and jurisdiction, with the Supreme Court deeming the order interlocutory, as it did not resolve all justiciable issues. Consequently, the Supreme Court dismissed the appeal under Rule 29(b), affirming that the appeal was not timely filed within the permissible period, thus lacking jurisdiction to proceed. This decision underscores the procedural imperatives of adhering to appeal deadlines and distinguishing between interlocutory and final orders in liquidation contexts.

Legal Issues Addressed

Appeal Timeliness and Jurisdiction

Application: Cohen's appeal was dismissed due to his failure to file within the required timeframe, as the order was considered interlocutory.

Reasoning: Consequently, the Supreme Court determined that it lacked jurisdiction to hear the interlocutory appeal due to Cohen’s failure to comply with the appeal deadline. Therefore, the appeal was dismissed under Supreme Court Rule 29(b).

Interlocutory vs. Final Orders

Application: The Supreme Court ruled that the order was interlocutory because it did not resolve all matters, thus Cohen's appeal was not timely and lacked jurisdiction.

Reasoning: Cohen argued that the order was final because it barred him from suing the Receiver. However, the Receiver contended that the order was interlocutory, and the Supreme Court agreed, emphasizing that the order did not resolve all justiciable matters and that Cohen’s objections would be addressed under the existing plans.

Objections to Receiver's Determinations

Application: Jeffrey Cohen's objections to the Receiver's determinations were considered an inappropriate attempt to start independent proceedings and were thus denied by the Court.

Reasoning: Jeffrey Cohen, IIC's founder, filed objections to the Receiver's determinations and sought permission to file a complaint against the Receiver, but the Court denied these motions on April 14, 2022, stating that Cohen's actions were an inappropriate attempt to initiate independent proceedings within the liquidation process.

Receivership and Liquidation Proceedings

Application: The Court of Chancery designated the Delaware Insurance Commissioner as the Receiver for the Indemnity Insurance Corporation, RRG, to manage the liquidation and claims process.

Reasoning: On April 10, 2014, the Delaware Court of Chancery issued a Liquidation and Injunction Order regarding the Indemnity Insurance Corporation, RRG (IIC), designating the Delaware Insurance Commissioner as the Receiver.