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§ 362(d)(3)

Walk Hill/Canterbury Dev., LLC, In re

Ruling
Court denied motion for an extension as debtor did not intend to file a plan of reorganizationand instead planned to seek dismissal of case after obtaining refinancing. (Bankr. D. Mass.)
Issue(s)
Automatic Stay; Relief from Stay; Acts Against Single Asset Real Estate by Secured

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Commercial opinion summary, case decided on April 18, 2019 , LexisNexis #0719-003

In re 231 Fourth Ave. Lyceum LLC

Ruling
Relief from stay granted where debtor could not meet plan obligations.
Issue(s)
Was plan proposed by single asset real estate debtor confirmable and if not was creditor entitled to relief from stay?

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Commercial opinion summary, case decided on February 28, 2014 , LexisNexis #0314-110

Phoenix Dev. & Land Inv. LLC v. SCBT

Ruling
Bankruptcy court did not err by treating creditor's entire claim as secured in denying confirmation and granting relief from stay.
Procedural posture

Chapter 11 debtor challenged a decision of the U.S. Bankruptcy Court for the Middle District of Georgia, which denied confirmation of its chapter 11 plan of reorganization and granted appellee secured creditor's motion for relief from the automatic stay.

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Commercial opinion summary, case decided on April 17, 2012 , LexisNexis #0512-078

In re Olde Prairie Block Owner LLC

Ruling
Single asset real estate case dismissed due to inability to propose feasible plan.
Procedural posture

A secured creditor of chapter 11 debtor filed a motion to modify the stay pursuant to 11 U.S.C.S. § 362(d)(3) or in the alternative to dismiss the debtor's chapter 11 single asset real estate case.

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Commercial opinion summary, case decided on March 14, 2012 , LexisNexis #0412-077

In re TTM MB Park LLC

Ruling
Geographically separate properties could not be considered "single asset real estate."
Procedural posture

This case was before the court on a creditor's motion for a determination that debtor was subject to the single asset real estate provisions of 11 U.S.C.S. § 362(d)(3). The court held a hearing on the motion and took the matter under advisement.

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Commercial opinion summary, case decided on March 12, 2012 , LexisNexis #0412-008

Meruelo Maddux Properties-760 S. Hill St. LLC v. Bank of Am. N.A. (In re Meruelo Maddux Props. Inc.)

Ruling
District court properly reversed bankruptcy court holding to find that there is no "whole business enterprise" exception to single asset real estate provisions of the Bankruptcy Code.
Procedural posture

A bankruptcy court refused to apply the single asset real estate provisions of 11 U.S.C.S. §§ 101(51B), 362(d)(3), to appellant debtor and its sister subsidiaries. The U.S. District Court for the Central District of California reversed, holding there was no whole enterprise exception, and granted appellee creditor relief from the automatic stay. The debtor appealed.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on January 27, 2012 , LexisNexis #0212-076

In re Light Foot Group LLC

Ruling
Debtor's five tracts of land constituted single asset real estate entitling creditor to relief from stay.
Procedural posture

This case filed under chapter 11 was before the court on the Joint Motion of two banks for a declaration that debtor was a single asset real estate entity subject to 11 U.S.C.S. § 362(d)(3). Debtor opposed the Motion, and at the conclusion of a hearing, at which debtor's manager testified, the court reserved decision.

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Commercial opinion summary, case decided on November 10, 2011 , LexisNexis #1211-076

In re Riverbend Cmty. LLC

Ruling
Debtor ordered to present amended, confirmable plan and pay postpetition interest to bank to avoid lifting of stay.
Procedural posture

Before the court in debtor's chapter 11 case was the motion of a bank for relief from the automatic stay pursuant to 11 U.S.C.S. § 362(d)(3). Debtor also sought approval of a sale to an insider.

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Commercial opinion summary, case decided on November 09, 2011 , LexisNexis #1211-007

In re Bucktown Station LLC

Ruling
Relief from stay denied to creditor bank in single asset real estate case where debtor's plan showed reasonable possibility of successful reorganization.
Procedural posture

Debtor filed a petition under chapter 11 of the Bankruptcy Code, indicating that its case involved single asset real estate, putting the case on a fast time line under 11 U.S.C.S. § 362(d)(3). Creditor bank moved to modify the stay.

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Commercial opinion summary, case decided on August 17, 2011 , LexisNexis #0911-115

In re Prosperity Park LLC

Ruling
Relief from stay to proceed against debtor's property granted where debtor's chapter 11 plan could not be confirmed.
Procedural posture

In a Chapter 11 bankruptcy case, a debtor filed a motion seeking to confirm its first amended disclosure statement and plan of reorganization. A bank filed a motion seeking relief from the automatic stay.

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Commercial opinion summary, case decided on May 17, 2011 , LexisNexis #0611-042