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§ 362(a)(1)

Scientific Weight Loss LLC v. U.S. Med. Care Holdings LLC

Ruling
Filing of amended complaint against debtor trademark owner violated stay.
Procedural posture

Plaintiffs, a franchisee with an allegedly exclusive license and three managing members, sued defendants, a trademark owner and related individuals and entities. Plaintiffs alleged twelve causes of action, including unfair competition, fraud, and breach of contract. Pending before the court were plaintiffs' application for a temporary restraining order (TRO) and plaintiffs' ex parte motion for leave to file a second amended complaint (SAC).

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Commercial opinion summary, case decided on October 22, 2008 , LexisNexis #1108-111

Hoang v. Urban Purchasing LLC

Ruling
Motion to stay Fair Labor Standards Act case against debtor's co-defendant denied absent direct connection or identity of interest.
Procedural posture

Plaintiff former employees brought an action against defendants, two employer companies and their principals, alleging that defendants failed to pay overtime wages required by the Fair Labor Standards Act by improperly classifying the employees as independent contractors. One company filed a bankruptcy petition, and the remaining co-defendants moved to stay all proceedings pursuant to the automatic bankruptcy stay of 11 U.S.C.S. § 362(a)(1).

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Commercial opinion summary, case decided on May 08, 2008 , LexisNexis #0608-073

Dunnam v. Sportsstuff Inc.

Ruling
Products liability stayed against third-party defendant due to indemnity agreement with debtor.
Procedural posture

In a product liability case between diverse parties, defendant recreational marine products manufacturer filed for chapter 11 bankruptcy protection, which, pursuant to 11 U.S.C. § 362(a)(1), automatically stayed proceedings as to it. The matter was before the federal district court on defendant retailer's motion to stay proceedings.

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Commercial opinion summary, case decided on January 23, 2008 , LexisNexis #0208-076

Haughton v. Alipio (In re Alipio)

Ruling
Strict foreclosure conducted by condominium association without notice of bankruptcy was void.
Procedural posture

Movants, an individual and a corporation, as a nominee for a mortgage company, reopened a former chapter 7 proceeding against respondent debtor after the debtor had received a discharge. The movants filed a motion to annul an automatic stay of the state court foreclosure proceedings pending on the debtor's condominium unit.

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Consumer opinion summary, case decided on November 29, 2007 , LexisNexis #0108-092

In re Cochonour

Ruling
Administrator of decedent's estate violated stay by filing forgery action against debtor.
Procedural posture

A chapter 7 debtor claimed that a decedent's estate and an attorney who represented the estate violated the automatic stay provision of 11 U.S.C. § 362, he filed a motion to impose sanctions, pursuant to 11 U.S.C. § 362(k), on the estate and the attorney. The estate and the attorney opposed the motion.

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opinion summary, case decided on August 02, 2007 , LexisNexis #0807-110

Midkiff v. Lowes Home Ctrs. Inc.

Ruling
Action against store that sold collapsed ladder subject to stay in manufacturer's bankruptcy.
Procedural posture

Plaintiff customer asserted a breach of warranty claim pursuant to the Uniform Commercial Code, Va. Code Ann. §§ 8.01-1 et seq. (2006), against defendant store to recover damages for injuries she sustained when a ladder she purchased from the store collapsed while in use. Before the court was the store's motion for summary judgment or, in the alternative, to stay proceedings pending the outcome of a manufacturer's bankruptcy proceedings.

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opinion summary, case decided on July 30, 2007 , LexisNexis #0807-109

Live Nation Worldwide Inc. v. GTA Inc.

Ruling
Creditor could proceed against guarantor without first proceeding against debtor.
Procedural posture

A debtor executed a sublease whereby it agreed to sublease from plaintiff corporation. Concurrently with the sublease, defendant guarantor entered into a guaranty. The debtor filed a petition for relief under chapter 11. The corporation sued the guarantor to enforce the unconditional guaranty of payment. The corporation moved for summary judgment under Fed. R. Civ. P. 56.

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opinion summary, case decided on May 18, 2007 , LexisNexis #0607-107

In re Healthessentials Solutions Inc.

Ruling
Automatic stay applied to government lawsuit under False Claims Act.
Procedural posture

The United States (Government) filed a motion seeking entry of an order declaring that the automatic stay of 11 U.S.C. § 362(a)(1) did not apply to the Government's pursuit of a lawsuit under the False Claims Act, 31 U.S.C. § 3729-33.

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opinion summary, case decided on May 17, 2007 , LexisNexis #0607-124

Huskey v. Allen County Farmers Servs.

Ruling
Stay violation could not be grounds for dismissal of personal injury case where debtor's prior conduct in the action was inconsistent with stay defense.
Procedural posture

Plaintiffs, a husband and wife, sued defendants, a farm supplier and a wire company, for damages from an alleged injury the husband received when wire was unloaded from his truck. Prior to the suit, the wire company filed for bankruptcy and a stay was issued pursuant to 11 U.S.C. § 362(a)(1) pending the bankruptcy's resolution. Before the federal district court were the wire company's motions for summary judgment and to file an amended answer.

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opinion summary, case decided on September 05, 2006 , LexisNexis #1006-050

In re Steward

Ruling
Co-op association and its attorney violated the automatic stay by continuing to pursue the removal of the debtor as executor of a probate estate in state court.
Procedural posture

The debtor moved pursuant to 11 U.S.C. § 362(a) for a determination that a co-op association and its attorney were in violation of the automatic stay by continuing to pursue the removal of the debtor as executor of a probate estate in state court. The violation was willful and warranted an award of attorney's fees and costs.

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opinion summary, case decided on February 24, 2006 , LexisNexis #0306-080