Tiffany Payne Geyer

Partner

Orlando
T +1.407.649.4079
F +1.407.841.0168

"Tiffany Payne [Geyer] exhibits 'a really great capacity to get to the bottom line and foster resolutions.' Commentators also praise her 'excellent writing skills.'"

— Chambers USA 2015

Overview

Tiffany Payne Geyer practices primarily in the areas of bankruptcy and creditors’ rights. Tiffany represents corporate and individual debtors in Chapter 11 cases, and individuals in Chapter 7 cases. Her clients include healthcare and hospitality businesses, medical professionals, investment bankers and financial advisors. Tiffany also has experience representing debtors in the energy sectors. Tiffany has negotiated settlements of guarantor liability, resolved numerous business disputes out of court, and has experience with assignments for the benefit of creditors. She has represented Chapter 11 trustees, examiners, secured creditors, unsecured creditors, landlords and panel trustees.

Select Experience

  • Served as co-lead counsel to the Chapter 11 Trustee in 11 jointly administered cases pending in the Eastern District of Kentucky, assisting in the Trustee’s efforts to obtain control of assets and retain estate professionals, and working with attorneys from the Department of Health and Human Services to resolve objections to the Trustee’s sale of a hospital and nursing school. Ms. Geyer served as lead counsel to the Trustee in an adversary proceeding against the Small Business Association, winning a temporary restraining order enabling the Trustee to obtain over $5.5 million in Paycheck Protection Program funds for the benefit of St. Alexius Hospital, located in an economically depressed area of St. Louis, Missouri. In re Americore Holdings, LLC, et. al, Case No. 19-61608; St. Alexius Hospital Corp. #1, v. Jovita Carranza, as Administrator for the U.S. Small Business Administration, Case. No. 20-ap-06005.
  • Served as lead counsel to judgment creditor, PC Services, LLC, and prevailed on a motion to terminate the exclusivity period, allowing PC Services to propose a creditor plan which was confirmed with the support of all of the Debtor’s constituents, effectuating a global resolution of claim objections, adversary proceedings, and an appeal of PC Services’ judgment. In re Cascades of Groveland HOA, Inc., Case No. 6:19-bk-04077-KSJ; In re Cascades of Groveland HOA, Inc. v. PC Services, LLC, 6:19-ap-00353-KSJ.
  • Represented Black Knight Financial Solutions as creditor and party to executory contract in a Chapter 11 case filed in the Southern District of New York by mortgage originator Ditech Holding Corp. Ms. Geyer filed a motion to compel Ditech to assume a multi-year agreement with Black Knight on an accelerated timetable, and negotiated the assumption of Black Knight’s contract, resolving outstanding contingent claims of over $20 million in Black Knight’s favor. In re Ditech Holding Corp, et al, 19-bk-10412-JLG.
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Experience

  • Served as co-lead counsel to the Chapter 11 Trustee in 11 jointly administered cases pending in the Eastern District of Kentucky, assisting in the Trustee’s efforts to obtain control of assets and retain estate professionals, and working with attorneys from the Department of Health and Human Services to resolve objections to the Trustee’s sale of a hospital and nursing school. Ms. Geyer served as lead counsel to the Trustee in an adversary proceeding against the Small Business Association, winning a temporary restraining order enabling the Trustee to obtain over $5.5 million in Paycheck Protection Program funds for the benefit of St. Alexius Hospital, located in an economically depressed area of St. Louis, Missouri. In re Americore Holdings, LLC, et. al, Case No. 19-61608; St. Alexius Hospital Corp. #1, v. Jovita Carranza, as Administrator for the U.S. Small Business Administration, Case. No. 20-ap-06005.
  • Served as lead counsel to judgment creditor, PC Services, LLC, and prevailed on a motion to terminate the exclusivity period, allowing PC Services to propose a creditor plan which was confirmed with the support of all of the Debtor’s constituents, effectuating a global resolution of claim objections, adversary proceedings, and an appeal of PC Services’ judgment. In re Cascades of Groveland HOA, Inc., Case No. 6:19-bk-04077-KSJ; In re Cascades of Groveland HOA, Inc. v. PC Services, LLC, 6:19-ap-00353-KSJ.
  • Represented Black Knight Financial Solutions as creditor and party to executory contract in a Chapter 11 case filed in the Southern District of New York by mortgage originator Ditech Holding Corp. Ms. Geyer filed a motion to compel Ditech to assume a multi-year agreement with Black Knight on an accelerated timetable, and negotiated the assumption of Black Knight’s contract, resolving outstanding contingent claims of over $20 million in Black Knight’s favor. In re Ditech Holding Corp, et al, 19-bk-10412-JLG.
  • Served as counsel to court-appointed Examiner in the Chapter 11 case of IPS Worldwide, LLC, a freight audit and payment services provider with debts exceeding $100 million. Ms. Geyer assisted the Examiner in tracing monies flowing through the Debtor’s domestic and international accounts, and proposed procedures approved by the court which facilitated settlement agreements with the estate’s numerous creditors, resolving approximately $20 million in competing claims. In re IPS Worldwide, LLC, Case No. 6:19-bk-0511-KSJ.
  • Represented Worldpay from FIS, one of the largest payment processors on the globe, as a creditor and as a party to executory contracts in the Chapter 11 cases of In re Grupo Aeromexico, S.A.B. de C.V., et al, Case No. 20-bk-11563 (S.D.N.Y.), and In re Cinemex USA Real Estate Holdings, Inc. et al (S.D.Fla.), negotiating the Debtors’ swift assumption of Worldpay’s contacts and cure costs.
  • Advised and assisted Debtors in 67 jointly administered Chapter 11 cases pending under the lead case In re Uplift RX, LLC, Case No. 17-32186 in the Southern District of Texas, Houston Division, in connection with investigations by several state pharmacy boards regarding prescription drug wholesale, and successfully defending Debtors against termination of pharmacy network provider agreements.
  • Served as lead counsel to the holder of an assignment of benefits of an insurance claim, prevailing against a condominium association which filed a Chapter 11 case and adversary proceeding seeking a declaratory judgment that the assignment was invalid, or subject to rejection as an executory contract. In re Chadham by the Sea Homeowner’s Association, Inc., Case No. 6:17-bk-00520-KSJ; Adv. Pro. 6:17-ap-00029-KSJ.
  • Served as lead counsel to Chapter 11 debtor, a provider of behavioral health services, and confirmed a Chapter 11 reorganization plan after resolving multimillion-dollar False Claims Act liability with the Medicaid Fraud Control Unit (“MFCU”) of the Office of Attorney General, obtaining MFCU’s vote in favor of plan confirmation. In re Behavioral Support Services, Case No. 6:15-bk-04855-KSJ.
  • Drafted expert report on the reasonableness of attorney’s fees for U.S. Bank as Trustee of an Indenture Trust (“Trustee”) for Fiddler’s Creek Community Development District (“CDD”). The case involved multiyear litigation between a developer, the CDD and the bondholders, and the firm was retained as an expert to review and prepare a report on the reasonableness of fees incurred by the Trustee for representation in 28 Chapter 11 cases. The case resolved on terms favorable to the Trustee shortly after the expert was deposed in connection with the report.
  • Represented Tampa law firm in negotiating favorable resolution of three sanctions motions against the firm involving six years of protracted litigation, multiple adversary proceedings, and appeals in a corporate Chapter 7 case. In re C.D. Jones & Company, Inc., Case No. 3:09-31595-LMK; Adv. Pro. No. 3:11-ap-03045-KKS; Adv. Pro. No. 3:15-03002-KKS; Adv. Pro. No. 3:15-03007-KKS.
  • Served as lead counsel to unsecured creditor in successful effort to obtain dismissal of an individual Chapter 11 case following trial. In re Walden, Case No. 6:16-bk-06346-CJJ.
  • Drafted, litigated and prevailed on motion for stay pending appeal resulting in stay of district court order reversing bankruptcy court order confirming the Chapter 11 plan of skilled nursing facility (“SNF”) during pendency of SNF’s appeal to the Eleventh Circuit. In re Bayou Shores, SNF, LLC; 2015 WL 6502704; 8:14-bk-9521-MGW, 8:14-cv-02816-T-30, 8:14-cv-02617-T-30, 8:15-cv-00103-T-30, 8:15-cv-00128-T-30.
  • Drafted successful objections to administrative claims of working interest owners, resulting in the disallowance of multiple multimillion-dollar administrative claims, assisting debtor in obtaining the confirmation of the Chapter 11 plan. In re Black Elk Energy Offshore Operations, LLC, Case No. 15-34287.
  • Served as lead counsel confirming “dirt for debt” Chapter 11 reorganization plan in a husband and wife joint Chapter 11 case, obtaining full discharge of pre-petition district court judgment against the debtors on personal guaranties and the release of garnishments after drafting and filing motion for relief from judgment in district court. In re Parker, Case No. 6:13-bk-11798-CCJ; Case No. 6:12-cv-539-Orl-37.
  • Served as Chapter 7 debtor’s counsel for investment bankers and financial advisors in individual Chapter 7 cases, obtaining discharge of FINRA arbitration awards.
  • Served as Chapter 7 debtor’s counsel for a cosmetic surgeon, obtaining discharge and settlement of wrongful death claims.
  • Served as lead counsel to landlord in successful effort to obtain dismissal of a corporate Chapter 11 case. In re Devroc Homes, Inc., 6:12-bk-01359-KSJ.
  • Served as lead counsel to a secured creditor in a single asset real estate (SARE) case to achieve relief from stay causing dismissal of a corporate Chapter 11 case with a one-year injunction against re-filing. In re Daytona Ocean Sands, LLC, 6:11-bk-13651-KSJ.
  • Drafted a successful motion for stay pending appeal, resulting in the stay of a New York statute and order directing closure of reorganized, substantively consolidated, Chapter 11 nursing home debtors. In re Legacy Healthcare, LLC, Case No. 1-05-11270-MJK; Legacy Healthcare, LLC, et al., vs. The State of New York, et al., 09-cv-1103.
  • Drafted an appellate brief obtaining Eleventh Circuit’s reversal of a district court order. Bond Safeguard v. Ward, Case No. 11-12646-AA (11th Cir. 2012).
  • Assisted lead counsel in obtaining confirmation of Chapter 11 plans reorganizing more than $200 million in debt for two timeshare developers. Island One Resorts, Inc., et al. Lead Case No. 6:10-bk-16177-KSJ; Tempus Resorts International LTD., et al., Lead Case No. 6:10-bk-20709-KSJ.

Recognitions and Memberships

Recognitions

  • Chambers USA: Bankruptcy/Restructuring in Florida (2014 to 2020)
    • Band 4 (2020), Band 5 (2017 to 2019), Up & Coming (2014 to 2016)
  • The Best Lawyers in America© (2020)
    • Florida: Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law
  • Florida "Super Lawyer" (2019 to 2020)

Memberships

  • American Bankruptcy Institute Caribbean Insolvency Symposium: Advisory Board Member (2018 to Present)
    • ABI CIS Sponsorship Co-Chair (2019 to Present)
  • Central Florida Bankruptcy Law Association (CFBLA)
  • Federal Bar Association
  • American Bar Association
  • International Women’s Insolvency & Restructuring Confederation (IWIRC)

Community

  • Children's Home Society, Central Florida Division
    • Advisory Board Member (2016 to 2020)
    • Board Member of the Year (2017)
    • Co-Host, 2020 Virtual Evening of Hope Gala, benefitting residents of The Faine House, which provides a home for youth who have aged out of foster care without being adopted, raising approximately $260,000 from virtual donors.
    • Chair, 2019 Evening of Hope Gala, benefitting residents of The Faine House, raising over $360,000 at event attended by approximately 600 members of the Central Florida community.
    • Vice Chair, 2018 Evening of Hope Gala benefitting residents of The Faine House, raising over $350,000 at event attended by approximately 600 members of the Central Florida community.
    • Won second-place fundraising award for Run for Hope benefitting residents of The Faine House (2019).
    • Won third-place fundraising award for Run for Hope benefitting residents of The Faine House (2017 and 2018).
  • March of Dimes Executive Team for Signature Chef Auction: Member (2018)
  • Juvenile Diabetes Research Foundation: Gala Committee (2012 to 2015)
  • Coordinated Baker Hostetler’s employee fundraising efforts to deliver direct financial support to employees of the Pulse Nightclub following the 2016 mass shooting in Orlando, distributing over $20,000 directly to Pulse’s employees in under 5 days.

Pro Bono

  • Represented pro se debtor as defendant in an adversary proceeding in which a creditor sought to except a debt from discharge pursuant to 11 U.S.C. § 523(a)(2). Ms. Geyer prevailed on a motion to dismiss the complaint for failing to state a cause of action. In re John L. Swafford, Jr., Case No. 6:19-bk-02536-KSJ, AMA Systems, LLC, v. Swafford, Adv. Pro. No. 6:19-ap-00275-KSJ.

Admissions

  • U.S. Court of Appeals, Eleventh Circuit, 2012
  • U.S. District Court, Northern District of Florida, 2016
  • U.S. District Court, Southern District of Florida, 2012
  • U.S. District Court, Middle District of Florida, 2002
  • Florida

Education

  • J.D., University of Florida Levin College of Law, 2000; Book Award for Legal Drafting; Member of Trial Competition Team
  • B.A., Political Science and Public Administration, University of Central Florida, 1998, with honors