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§ 362(d)(3)

In re Erie Playce LLC

Ruling
Chapter 11 debtors could pay contract rate of interest to mortgagee pending confirmation of plan within reasonable time.
Procedural posture

Debtor was a single asset real estate debtor. It filed a voluntary petition for relief under Chapter 11 of the Bankruptcy Code. An assignee from a secured creditor holding a mortgage on real estate owned by debtor filed an objection to debtor's Motion to Direct the Receiver to Make Payments to the Assignee and Related Relief (Motion) under 11 U.S.C.S. § 362(d)(3).

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Commercial opinion summary, case decided on December 07, 2010 , LexisNexis #0111-002

In re Northern Outer Banks Assocs. LLC

Ruling
Relief from stay granted in single asset real estate case where debtor had not filed plan or commenced interest payments.
Procedural posture

Debtor, a North Carolina limited liability company, filed a petition under Chapter 11 of the Bankruptcy Code, and a bank filed a motion for relief from the stay that was imposed pursuant to 11 U.S.C.S. § 362 when the debtor declared bankruptcy or, in the alternative, for adequate protection. The debtor opposed the bank's motion.

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Commercial opinion summary, case decided on November 08, 2010 , LexisNexis #1210-042

In re Spencer Creek Props.

Ruling
Creditor bank granted relief from stay in single asset real estate case.
Procedural posture

A creditor bank sought a determination whether the case was a "single asset real estate" (SARE) case as defined in the 11 U.S.C.S. § 101(51B), thus whether relief from the automatic stay was applicable under 11 U.S.C.S. § 362(d)(3).

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Commercial opinion summary, case decided on October 25, 2010 , LexisNexis #1210-005

In re RIM Dev. LLC

Ruling
Relief from stay granted allow creditor to enforce security interest where debtor failed to propose plan with reasonable possibility of confirmation.
Procedural posture

A debtor in a single asset real estate case proposed successive plans for completion of the debtor's planned residential and commercial development with payments to secured creditors. A creditor secured by certain town homes in the development moved for relief from the automatic bankruptcy stay pursuant to 11 U.S.C.S. § 362(d)(3)(A) to allow the creditor to enforce its security interest.

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Commercial opinion summary, case decided on August 13, 2010 , LexisNexis #1010-011

In re Crown Ohio Invs. LLC

Ruling
Relief from stay granted conditioned upon debtor's default under interest payment agreement.
Procedural posture

Movant, a creditor mortgagee, filed a motion for relief from the automatic stay pursuant to 11 U.S.C.S. § 362(d). The respondent, a single-asset real estate chapter 11 debtor, filed an opposition to the motion. However, the parties stipulated to a monthly interest payment pursuant to 11 U.S.C.S. § 362(d)(3)(B)(ii) of $ 9,474.95.

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Commercial opinion summary, case decided on March 12, 2010 , LexisNexis #0610-043

In re Harmony Holdings LLC

Ruling
Project encompassing several tracts of land and two entities as owners qualified as "single asset real estate."
Procedural posture

Creditors filed motions to determined whether the cases were single asset real estate cases for purposes of 11 U.S.C.S. § 362(d)(3).

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Commercial opinion summary, case decided on June 23, 2008 , LexisNexis #0908-004

In re Webb MTN LLC

Ruling
Multiple development projects planned for five tracts of land were actually part of one large development which constituted single asset real estate.
Procedural posture

Creditors of a chapter 11 debtor sought a determination that the assets of the debtor constituted single asset real estate under 11 U.S.C.S. § 362(d)(3).

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Commercial opinion summary, case decided on March 06, 2008 , LexisNexis #0408-110

In re Windwood Heights Inc.

Ruling
Relief from stay to allow foreclosure in "single asset real estate" case denied where possibility for equitable plan existed.
Procedural posture

Debtor developer filed a petition under chapter 11 of the Bankruptcy Code in the State of New Jersey, and the case was transferred to the Northern District of West Virginia. A judgment creditor filed a motion for relief from the automatic stay, pursuant 11 U.S.C.S. § 362(d)(3). The debtor opposed the motion.

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Commercial opinion summary, case decided on February 25, 2008 , LexisNexis #0308-112

HOC Group of Timber Noteholders v. Pacific Lumber Co. (In re Scotia Pac. Co. LLC)

Ruling
Debtor engaged in timber sales was not a single asset real estate debtor and was not subject to expedited proceedings.
Procedural posture

The bankruptcy court denied a motion by creditors to expedite bankruptcy proceedings under 11 U.S.C. § 362(d)(3), finding the chapter 11 debtor was not a "single asset real estate" ("SARE") under 11 U.S.C. § 101(51B). The creditors appealed, then sought certification from the bankruptcy court to the court of appeals under 28 U.S.C. § 158(d)(2). The District Court for the Southern District of Texas then certified the appeal.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on November 13, 2007 , LexisNexis #1207-004

Four J Funding LLC v. Land Pres. LLC (In re Land Pres. LLC)

Ruling
Relief from stay to allow foreclosure granted in single asset case.
Procedural posture

Secured creditor filed a motion for relief from the automatic stay to permit the creditor to continue with a pending state-court foreclosure action. The motion asserted that the debtor's case was a single asset real estate case under 11 U.S.C. § 362(d)(3), that the debtor lacked equity in the property; and that the property was not necessary for a reorganization.

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opinion summary, case decided on July 02, 2007 , LexisNexis #0807-038