Resolve insolvency cases

I have the creditor list, the insolvency filings, and the cashflow forecast. Prepare the insolvency resolution file and send it to Helen in restructuring and to the lead insolvency counsel for e-signature, in that order, to meet Monday morning's creditors' meeting — but first confirm the cash waterfall and that secured creditor ranks match the filing.

Before I present the proposed resolution to the creditors, make it easy for skeptical bank lawyers to approve: show the cash waterfall on one page, surface the recovery percentages for each creditor class, make any covenant waivers obvious, and flag wording that would trigger a cross-default clause.

At 4pm a secured lender emailed disputing their ranking in our proposed cash waterfall; the insolvency judge needs a position paper tomorrow. I am responsible for the ranking, counsel expects our legal argument, and I cannot prove the pre-petition security priority quickly. What is the most defensible short-term course of action to present to the judge and the creditors' committee?

Across five recent insolvency cases we lose three to five days resolving creditor priority disputes at the last minute, which delays distributions and increases legal fees. Where are we most likely failing — documentation, client instructions, or pre-filing creditor analysis — and what one change in our pre-filing checklist will save the most time?