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In Re Chicken Soup For The Soul Entertainment Inc

                  IN THE UNITED STATES DISTRICT COURT 
                     FOR THE DISTRICT OF DELAWARE 
IN RE CHICKEN SOUP FOR THE SOUL 
ENTERTAINMENT INC.   et ai.,                   :   Chapter 7 
                                            :   Case No. 24-11442 (MFW) 
               Debtors.                     :   (Jointly Administered) 
CHARLES MUSZYNSKI,                             : 
               Appellant,                   : 
        v.                                  : 
GEORGE MILLER, solely in his capacity as       :   Civ. No. 25-52-GBW 
Chapter 7 Trustee,                             : 
               Appellee. 

                              MEMORANDUM 
I.     INTRODUCTION 
   This dispute arises in the Chapter 7 cases of debtor Chicken Soup for the Soul, Inc. and certain 
of its affiliates (together, the “Debtors”).  Appellee George L. Miller, in his capacity as Chapter 7 
Trustee for the Debtors’  estates, seeks to dismiss (D.I.  8) (the “Motion to Dismiss”) the above- 
captioned appeal filed by pro se appellant Charles Muszynski (the “Appellant”) with respect to the 
Bankruptcy Court’s January 14, 2025 Order (Bankr. D.I. 547)! (the “Retention Order”), which (i) 
granted the Trustee’s application to retain Culpepper IP, LLLC (the “Culpepper Firm”), as special 
counsel to pursue copyright litigation; and (ii) overruled Appellant’s objection to the application. 
   In his Motion to  Dismiss, the Trustee  asserts that Appellant lacks  appellate standing to 
challenge the Retention Order.  The Trustee further asserts that the appeal of the Retention Order 
must be dismissed because it is an appeal of an interlocutory order, and Appellant has not sought 
leave pursuant to Rule 8004(2)(a) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy 

The docket of the Chapter 7 cases, captioned Jn re Chicken Soup for the Soul Entertainment Inc., 
et al., No. 24-11442 (MFW) (Bankr. D. Del.), is cited herein as “Bankr. D.J.__.”

Rules”).  Even assuming that this Court treats Appellant’s Notice of Appeal as a motion for leave to 
appeal pursuant to Federal Rule of Bankruptcy Procedure 8004(d)(1), the Trustee asserts that there is 
no basis for this Court to grant such leave.  For the reasons set forth herein, the appeal of the Retention 
Order shall be dismissed for lack of appellate standing. 
II.     BACKGROUND 
   On June 29, 2024 (the “Petition Date”), the Debtors filed voluntary petitions for relief under 
chapter  11  of the Bankruptcy Code.  On July  10, 2024, the Bankruptcy Court entered an Order 
converting the cases from chapter 11 to chapter 7 of the Bankruptcy Code effective as of July 10, 
2024.  On July 11, 2024, the United States Trustee for Regions 3 and 9 appointed the Trustee as the 
Chapter 7 trustee of the Debtors’ estates. 
   Prior to the Petition Date, the Debtors comprised one of the largest advertising-supported 
video-on-demand companies in the United States, with three flagship streaming services: Redbox, 
Crackle, and Chicken Soup for the Soul. Through Debtor Redbox Automated Retail LLC, the Debtors 
operated  (i)  Redbox  Free  Live  TV,  a  free  ad-supported  streaming  television  service  with 
approximately  180  channels,  (ii)  a transaction video-on-demand  service,  and  (iii)  a network of 
approximately 24,000 kiosks across the United States for DVD rentals. 
   Also  prior to the Petition Date,  Debtor Screen Media Ventures,  LLC  (“Screen Media”) 
retained the Culpepper Firm to pursue copyright infringement litigation against various internet 
service providers.  Specifically, the Culpeper Firm represented Screen Media, together with other 
plaintiffs, in litigation in the United States District Court for the Southern District of Florida against 
certain internet service providers, including Appellant and/or companies owned directly or indirectly 
by Appellant  1701  Management LLC  d/b/a LiquidVPN,  for alleged copyright infringement.  It 
appears undisputed that Screen Media ultimately obtained a judgment against Appellant for $250,000 
(the “Judgment”) in that litigation.  See Millennium Funding, Inc., et al. v.   1701 Management LLC,

et  al.,  21-cv-20862-BB  (S.D.  Fla.  Mar.  25,  2022),  D.I.  213  (default judgment  and permanent 
injunction). Appellant later filed a Chapter 7 bankruptcy in Puerto Rico, seeking to have the Judgment 
discharged; Appellant’s Chapter 7 case was dismissed, however, and Appellant is currently appealing 
that order.  See In re Charles Muszynski, Case No. 23-02870 (MCF) (Bankr. D.P.R. May 21, 2024), 
D.I. 185 (order dismissing Appellant’s Chapter 7 case); Muszynski v. Millennium Funding, Inc., et 
al., Case No. 24-11 (1st Cir. B.A.P. May 21, 2024) (Appellant’s appeal of the order dismissing his 
Chapter 7 case).  As of the Petition Date, the Culpepper Firm continued to represent Debtor Screen 
Media, together with its co-plaintiffs, in litigation to enforce the Judgment.  Among other things, the 
Culpepper Firm sought to have the Judgment recognized and enforced in Nevis, where Appellant 
resides, leading to additional litigation.  (See D.I. 8 at 3 (citing Millennium Funding, Inc.,  et al. v. 
AUH20, LLC, et al., Claim No. NEVHCV2022/0183 (Eastern Caribbean Supreme Court in The High 
Court of Justice St. Christopher and Nevis, Nevis Circuit); D.I. 9 at 5 (listing same litigation); Bankr. 
D.I. 552, Transcript of hearing held on Jan. 8, 2025 (“1/8/2025 Tr.”) at 8:22-9:10).) 
   On December 6, 2024, the Trustee filed in the Bankruptcy Court an application seeking 
approval of the retention of the Culpepper Firm as special counsel (Bankr. D.J. 508) (the “Retention 
Application”) nunc pro tunc to the Petition Date.  Pursuant to the Retention Application, the Trustee 
sought authority to retain the Culpepper Firm pursuant to § 327(e) of the Bankruptcy Code to (i) 
continue  representing  Debtor  Screen  Media  in  the  Judgment  enforcement  litigation  with 
compensation based on a percentage of any recovery made on behalf of the Debtor, and (ii) represent 
the estates in any additional copyright infringement litigation that the Trustee may request that the 
Culpepper Firm pursue on behalf of the estates.  On December 26, 2024, Appellant filed the Objection 
to Trustee’s Engagement of Special Counsel, Request for Disqualification of Culpepper IP, LLLC 
Pursuant to 105, 327(e), and 328(a) Request for Sanctions (Bankr. D.I. 524) (the “Objection”).  The 
Objection made numerous allegations regarding the Culpepper Firm and attorney Kerry Culpepper,

including alleged conflicts of interest which, according to Appellant, disqualified the Culpepper Firm 
from representing the Debtors’ estates.  Although difficult to follow, the Objection alleged that the 
Culpepper Firm is funded by PML Process Management Limited (“PML”), and that PML is a “third- 
party litigation funding company” which “profits from copyright trolling as a business” through 
“unethical legal practices.”  (Objection at 2-5.)  The majority of the Objection alleges omissions and 
misrepresentations made by  attorney  Kerry  Culpepper and the Culpepper Firm  in the  Southern 
District of Florida litigation which gave rise to the  Judgment.  Relevant to the Retention Application, 
however,  Appellant’s  main  contentions  were  (1)  that  the  Culpepper  Firm’s  post-petition 
representation of Debtor Screen Media in the litigation to enforce the Judgment constituted a violation 
of the automatic stay because the representation was without Bankruptcy Court authorization; and (2) 
that Mr. Culpepper’s ownership of 42 Ventures, LLC—one of Screen Media’s co-plaintiffs in the 
Southern  District  of Florida  litigation—constituted  a  conflict  of  interest  that  disqualifies  the 
Culpepper Firm from representing the estates. 
   At a hearing on the Retention Application held on January 8, 2025, both the Trustee, through 
counsel, and Appellant, pro se, presented argument.  The Trustee asserted that Appellant’s Objection 
was baseless, and further argued that Appellant is not a creditor of the Debtors, not a party in interest 
in the bankruptcy cases, and therefore lacked standing to challenge the Trustee’s proposed retention 
of the Culpepper Firm on behalf of the estates.  (See 1/8/2025 Tr. at 7:17-8:13 (counsel to the Trustee 
asserting that Appellant is not a creditor of the estates but rather a “judgment debtor ... in connection 
with a $250,000 judgment which is held by the debtors”),  Indeed, Appellant conceded that he was 
not a creditor of the Debtors.  (/d. at 8:4-8:5 (THE COURT: “Well, you’re not currently a creditor, 
Mr. Muszynski.  You have no claim against the estate that’s been confirmed by any court or by this 
Court.”  MR. MUSZYNSKI: “Yes, ma’am.”).

   The Bankruptcy Court questioned Mr. Culpepper and also heard argument with respect to the 
litigation against Appellant and other issues raised in the Objection.  The Bankruptcy Court further 
allowed Appellant an opportunity to examine Mr. Culpepper with respect to matters bearing on the 
alleged conflicts of interest.  (See id. at 8:18-21:14.)  The Bankruptcy Court rejected Appellant’s 
argument that Kerry Culpepper “has continued to litigate in violation of ... the automatic stay in this 
case.”  (Jd.  at 30:13-23.)  As the Bankruptcy Court explained to Appellant, “the automatic stay 
protects the debtor, not the defendants he is suing.  A debtor can continue to prosecute actions against 
others.  The automatic stay protects the debtors and the debtor’s estate.  So I think you have it in 
reverse.  It doesn’t protect you.”)  (/d. at 20:19-23.)  Ultimately, the Bankruptcy Court approved the 
retention of the Culpepper Firm, finding that there were no conflicts of interest and that the terms of 
the retention were appropriate.  (See id.  at 22:6-23:3.)  “Section 327(e) allows a party who has 
previously represented the debtor to now represent the trustee in that same manner,” the Bankruptcy 
Court explained,  finding  it  “perfectly  appropriate  that the trustee has  selected to  continue  Mr. 
Culpepper’s representation.” (/d. at 22:22-23:1.) Regarding Appellant’s argument that the Culpepper 
Firm also represented 42 Ventures and other plaintiffs) in the Southern District of Florida litigation, 
the Bankruptcy Court did “not find any conflict in Mr. Culpepper representing this estate and the 
other plaintiffs in pursuing other parties that the other plaintiffs and the estate have similar claims 
against.”  (d. at 22:6-9.) 
   On  January  14,  2025,  the  Bankruptcy  Court  entered  the  Retention  Order,  overruling 
Appellant’s Objection and granting the Retention Application.  Appellant filed a timely Notice of 
Appeal.  (D.I. 4 (amended and corrected notice).)  On February 21, 2025, the Trustee filed the Motion 
to Dismiss.  (D.I. 8.)  On February 28, 2025, Appellant filed his response to the Motion to Dismiss 
(D.I. 9) (the “Response”).  On March 11, 2025, the Trustee filed his reply in further support of the 
Motion to Dismiss (D.I. 10) (the “Reply”).  On March 12, 2025, Appellant filed a Motion to Strike

the Trustee’s Reply (D.I. 11) (the “Motion to Strike”) on the basis that the Reply was untimely.  The 
Trustee did not respond to the Motion to Strike.?  No party requested oral argument. 
Ill.    DISCUSSION 
   Although the Bankruptcy Code does not contain a provision for appellate standing, the Third 
Circuit has recognized that standing is a prerequisite to proceeding on appeal.  See Jn re Richardson 
Indus. Contractors, Inc., 189 Fed. App’x 91, 92 (3d Cir. 2006) (citing Jn re Dykes, 10 F.3d 184, 187 
(3d Cir. 1993)).  Appellate standing in bankruptcy is limited to “persons aggrieved” by an order of 
the Bankruptcy Court.  Jn re Revstone Indus. LLC, 690 F. App’x 88, 89 (3d Cir. 2017) (citing Jn re 
Combustion Eng’g, Inc., 391 F.3d 190, 214 (3d Cir. 2004)).  The “persons aggrieved” test “now exists 
as a prudential standing requirement that  limits  bankruptcy  appeals to  persons  whose  rights  or 
interests are directly and adversely affected pecuniarily by an order or decree of the bankruptcy 
court.”  Combustion, 391 F.3d at 214 (internal quotation marks omitted).  To be a person aggrieved, 
a party must show that they are challenging an order that “diminishes their property, increases their 
burdens, or impairs their rights.”  Jd.  (internal quotation marks omitted).  This standard is “more 
restrictive than the case or controversy” standing requirement of Article III, with respect to which the 
injury “need not be financial and need only be fairly traceable to the alleged illegal action.”  /d. at 
215 (quoting Travelers Ins. Co. v. H.K. Porter Co., 45 F.3d 737, 741 (3d Cir. 1995) (internal quotation 

? Appellant’s Motion to Strikes seeks to strike the Trustee’s Reply on the basis that it was filed past 
the 7-day deadline set forth in Bankruptcy Rule 8013(a)(3)(B) (“Unless the district court or BAP 
orders otherwise ...  the movant may--within 7 days after the response is served--file a reply that 
addresses only matters raised in the response”). Appellant’s Certificate of Service attached to his 
Response indicates that it was delivered to the Court by “courier” and that it would be served on the 
Trustee “by way of the Court’s CM/ECF system.”  (D.I. 9-1.)  The date-stamped document reflects 
that this Court received Appellant’s Response to the Motion to Dismiss on February 28, 2025.  (See 
D.I. 9.)  However, the docket of the appeal reflects that the Response was not docketed by this Court 
and electronically accessible on the Court’s CM/ECF system until March 4, 2025.  The Trustee filed 
his Reply on March 11, 2025, and within 7 days of the Court’s docketing of Appellant’s Response. 
The Court finds no hardship or prejudice to the Appellant.  Accordingly, the Court will deny the 
Motion to Strike.

marks omitted).  Rather, the Third Circuit requites the appealing party to be “directly affected” by the 
order not  merely  “exposed  to  some  potential  harm  incident to  the  bankruptcy  court’s  order.” 
Combustion, 391  F.3d at 215.  “This more stringent appellate standing requirement rests on the 
‘particularly acute’ need to limit appeals in bankruptcy proceedings, which often involve a ‘myriad 
of parties . . . indirectly affected by every bankruptcy court order.”  Jd.  (quoting Kane v. Johns- 
Manville Corp., 843 F.2d 636, 642 (2d Cir. 1988)).  Whether an appellant is a “person aggrieved” is 
generally a question of fact for the district court.  See In re Dykes, 10 F.3d at 188. 
   While Appellant clearly takes issue with the merits of the underlying Judgment and litigation 
to enforce the Judgment, he has failed to show how he is “directly and adversely affected pecuniarily” 
by the Retention Order.  Appellant asserts his “pending claims” against the Debtors’ estates, but he 
points to no proof of claim he has filed against the Debtors nor does he explain how retention of 
special counsel affects those claims.  It appears that Appellant’s “pending claims” are in the nature of 
possible claims against the estates that he speculates may arise out of a possible dismissal of the 
already filed Nevis action to recognize and enforce the Judgment.  (See D.I. 9 at p. 16 of 21 (asserting 
“the Nevis case will be thrown out,” and as a result, “costs, fees, and penalties will be assessed to the 
Estates,  the Trustee,  and  Culpepper.”)   Even  assuming  Appellant’s prediction  proves  true,  the 
Retention Order does not prevent Appellant from recovering any such costs and fees, and the Trustee 
will still need special counsel to represent him in any such matter.  Simply put, the only apparent 
harm to Appellant is that the Culpepper Firm will continue to prosecute the Debtors’ causes of action 
against Appellant and attempt to recover on the  Judgment for the benefit of the Debtors’ estates.  But 
Appellant’s rights and interests are not “directly and adversely affected pecuniarily” by the retention 
of this particular law firm because any special counsel retained by the Trustee on behalf of the estates 
will continue the already filed Judgment enforcement litigation against Appellant.

   Appellant further asserts that the Trustee has contested Appellant’s standing for the first time 
in this appeal and therefore has somehow waived the argument.  (See D.I. 9 at 8-9 (asserting that 
arguments raised for the first time on appeal should be deemed waived).)  As an initial matter, 
regardless of whether it was raised below, this Court must be satisfied that Appellant has appellate 
standing—that he is “‘person[] aggrieved” by an order of the Bankruptcy Court—as a prerequisite to 
hearing the appeal.  See In re Richardson, 189 Fed. App’x at 92.  Moreover, Appellant’s argument 
that the issue of standing was never raised is belied by the record below, in which: (a) the Trustee, 
through counsel, asserted that Appellant lacked standing, as he was neither a creditor nor a party in 
interest (1/8/2025 Tr. at 7:17-7:24 (“Your Honor, I’ve parsed through pretty carefully the objection, 
and candidly I think that it’s not really comprehensible, nor does it make sense.  He is not a creditor, 
nor is he a party in interest.””); (b) Appellant admitted that the Trustee was correct (id. at 8:4-8:6 (“And 
I should also say I may not be a creditor of the estate yet, but when he presses the case in Nevis and 
it loses, they lose, I will become a creditor.”); and (c) the Bankruptcy Court agreed with the Trustee 
(id. at 8:10-8:12 (“Well, you’re not currently a creditor, Mr. Muszynski. You have no claim against 
the estate that’s been confirmed by any court or by this Court.”).) 
   Appellant  further points  to  Trustee’s  failure  to  object to  Appellant’s  filing  a notice  of 
appearance in the Chapter 7 cases and Appellant’s attendance and participation at various hearings. 
(See D.I. 9 at p. 9 of 21.)  “Appellee obviously waived ability to object,” Appellant argues, “by failing 
to timely do so at Appellant’s multiple earlier appearances.”  (/d.)  Again, this Court must determine 
as a threshold matter whether appellate standing exists, regardless of the bankruptcy proceedings. 
Appellant’s waiver argument is unavailing.  The Bankruptcy Code provides that “[a] party in interest, 
including the debtor, the trustee, a creditors’  committee, an equity security holders’ committee, a 
creditor, an equity security holder, or any indenture trustee, may raise and may appear and be heard 
on any issue in a case under this chapter.”  11 U.S.C. § 1109(b).  While this provision “confers broad

standing at the trial level,” “courts do not extend that provision to appellate standing.”  /n re PWS 
Holding Corp., 228 F.3d 224, 249 (3d Cir. 2000)).  So even assuming that Appellant was a party in 
interest with standing to be heard at the trial level, the appellate standard is necessarily more stringent 
based on the “particularly acute” need to  limit appeals in bankruptcy  proceedings:  “if appellate 
standing is not limited, bankruptcy litigation will become mired in endless appeals brought by the 
myriad of parties who are indirectly affected by every bankruptcy court order.”  Travelers, 45 F.3d at 
541 (quoting Kane v. Johns-Manville Corp., 843 F.2d 636, 642 (3d Cir. 1988),  That standard is not 
met here. 
   Appellant has failed to show that he is “directly and adversely affected pecuniarily” by the 
Retention Order and therefore lacks appellate standing to pursue the appeal.  Based on the foregoing, 
the  Court  need  not  address  the  parties’  arguments  regarding  whether  the  Retention  Order  is 
interlocutory. 
IV.    CONCLUSION 
   As Appellant lacks standing to appeal the Retention Order, and the appeal will be dismissed. 
An appropriate Order will be entered. 
Date:  July 22, 2025                                   ] 
                                      Se fn, 
                                 THE HONORABLE GREGORY B. WILLIAMS 
                                 UNITED STATES DISTRICT JUDGE