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§ 362(c)

U.S. Bank v. Robinson (In re Robinson)

Ruling
Postdismissal, pre-reinstatement foreclosure did not violate stay.
Issue(s)
Was foreclosure conducted between dismissal and reinstatement of debtor's case valid?

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Consumer opinion summary, case decided on October 24, 2014 , LexisNexis #0315-040

In re Reidy

Ruling
Debtor entitled to extension of stay in second case, where first case was dismissed, given clear and convincing evidence of good faith.
Issue(s)
Was debtor entitled to an extension of the automatic stay in its second case, filed after the first case was dismissed, where a creditor alleged a lack of good faith as the debtor had yet to file schedules, a statement of financial affairs or any proposed chapter 13 plan?

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Consumer opinion summary, case decided on September 24, 2014 , LexisNexis #1114-007

In re Pyburn

Ruling
In rem proceeding to reform deed of trust did not violate stay.
Issue(s)
Did order granting stay relief against real property give creditor the right to reform a deed of trust, signed by debtor but not by debtor spouse?

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Consumer opinion summary, case decided on May 21, 2014 , LexisNexis #0614-044

In re Gatlin

Ruling
Stay imposed in debtor's third case within one year due to good faith, except as to foreclosure sale prior to petition date that was completed postpetition.
Issue(s)
Should a stay be imposed in debtor's third case filed within one year, including as to foreclosure for which sale was completed prior to petition date but which became final postpetition?

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Consumer opinion summary, case decided on February 18, 2014 , LexisNexis #0314-044

In re Norris

Ruling
Stay imposed in debtor's third case due to rebuttal of presumption of bad faith.
Issue(s)
Was debtor entitled to a stay in third case filed within one year.

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Consumer opinion summary, case decided on December 31, 2013 , LexisNexis #0114-075

In re Zow

Ruling
Motion for relief from stay to proceed against abandoned property denied as moot.
Issue(s)
Is relief from stay necessary to proceed against property abandoned by chapter 7 trustee?

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Consumer opinion summary, case decided on August 27, 2013 , LexisNexis #0913-074

In re Williford

Ruling
Stay terminated in debtor's second case as to debtor and debtor's property but not as to property of the estate.
Procedural posture

The debtor filed a motion to extend the automatic stay, and the creditor filed a motion to confirm termination of the stay as to certain real property. The court denied the debtor's motion to the extent that it requested a retroactive reinstatement of the automatic stay, but it took under advisement the issue of whether the operation of 11 U.S.C.S. § 362(c)(3) terminated the entire automatic stay.

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Consumer opinion summary, case decided on July 17, 2013 , LexisNexis #0813-007

In re McLemore

Ruling
Untimely motion to extend stay in debtor's second case denied.
Procedural posture

A chapter 13 debtor filed a motion to extend the automatic stay pursuant to 11 U.S.C.S. § 362(c)(3).

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Consumer opinion summary, case decided on July 16, 2013 , LexisNexis #0813-008

Edwards v. THR Georgia LLC (In re Edwards)

Ruling
Reimposition of stay denied where foreclosure debtor sought to set aside had previously been validated.
Procedural posture

Debtor filed a petition under chapter 7 of the Bankruptcy Code and asked the court to extend the automatic stay until an adversary proceeding she filed pro se was resolved. The debtor argued that reimposition of the stay was appropriate because the requirements of O.C.G.A. § 44- 14-162.2 were not met when notice of an impending foreclosure was provided to her. 11 U.S.C.S. § 362(c)(3)(B) applied to her motion.

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Consumer opinion summary, case decided on May 08, 2013 , LexisNexis #0613-114

In re Vegt

Ruling
Relief from stay granted as to chapter 12 debtor's farm property not necessary to effective reorganization.
Procedural posture

Chapter 12 debtors filed a motion for authority to use cash collateral under 11 U.S.C.S. § 363. A secured creditor filed a motion to modify the automatic stay under 11 U.S.C.S. § 362(c)(1)-(2) or alternatively dismiss the chapter 12 cases. A second secured creditor filed a motion for relief from the stay.

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Consumer opinion summary, case decided on April 30, 2013 , LexisNexis #0513-074