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§ 546

Tops Holding II Corp., In re--Halperin v. Morgan Stanley Investment Mgmt.

Ruling
Dividends paid to investors for three years did not qualify as safe harbor transfers where therewas no qualifying transaction and no qualifying recipient had been identified. (Bankr.S.D.N.Y.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Judge or Jurisdiction information not available
Commercial opinion summary, case decided on October 12, 2022 , LexisNexis #1222-062

Sec. Inv. Prot. Corp. v. Bernard L. Madoff Inv. Sec. LLC

Ruling
Any defendant who actually knew about the debtor’s Ponzi scheme was not entitled to theprotections of the safe harbor against trustee’s efforts to recover subsequent transfers. (Bankr.S.D.N.Y.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Commercial opinion summary, case decided on September 27, 2022 , LexisNexis #1222-016

Sec. Investor Prot. Corp. v. Bernard L. Madoff Inv. Sec. LLC

Ruling
Defendants who actually knew that debtor was running a Ponzi scheme were not entitled tothe protections of the safe harbor. (Bankr. S.D.N.Y.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Commercial opinion summary, case decided on September 22, 2022 , LexisNexis #1122-088

BWGS, LLC, In re--Petr v. BMO Harris Bank, N.A.

Ruling
Motion to dismiss avoidance proceeding denied as trustee pleaded the necessary elements forrecovery against the creditor under state law. (Bankr. S.D. Ind.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Commercial opinion summary, case decided on August 18, 2022 , LexisNexis #1022-059

Samson Res. Corp., In re--Kravitz v. Samson Energy Co., LLC

Ruling
Petition date rather than transfer date determines when a party is a financial participant withrespect to the application of the safe harbor to redemption cash transfers. (Bankr. D. Del.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Commercial opinion summary, case decided on August 04, 2022 , LexisNexis #0922-089

Securities Inv. Prot. Corp. v. Bernard L. Madoff Inv. Sec. LLC

Ruling
Safe harbor did not bar the avoidance of initial transfers given allegations that the feeder fundtransferee had actual knowledge that the debtor was not trading securities. (Bankr. S.D.N.Y.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Commercial opinion summary, case decided on June 13, 2022 , LexisNexis #0822-015

Hebert, In re--Kaler v. Hebert

Ruling
Debtor's discharge was denied due to failure to disclose potentially preferential paymentsmade to her son or to establish that the payments were paid in the ordinary course ofbusiness. (Bankr. D.N.D.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Judge or Jurisdiction information not available
Consumer opinion summary, case decided on April 22, 2022 , LexisNexis #0622-061

Kelley v. Safe Harbor Managed Account 101, Ltd.

Ruling
Transfers to feeder fund that qualified as a financial institution would be excepted fromavoidance if found to be made in connection with a securities contract on remand. (8th Cir.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Judge or Jurisdiction information not available
Consumer opinion summary, case decided on April 21, 2022 , LexisNexis #0622-060

Matt Garton & Assocs., LLC, In re--Weinman v. Garton

Ruling
Debtor's motion to dismiss denied as he could not bootstrap the new transactions to thetransfers in the original complaint after the expiration of the § 546(a) statute of limitations.(Bankr. D. Colo.)
Issue(s)
Limitations on Avoiding Powers; Statute of Limitations.

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Commercial opinion summary, case decided on February 14, 2022 , LexisNexis #0522-018

450 S. Western Ave., LLC, In re--Philmont Mgmt. v. 450 S. Western Ave., LLC

Ruling
Bankruptcy court did not err in dismissing the complaint as it found that plaintiff had nottimely perfected its lien under California law nor had it preserved its lien by filing a timelynotice. (B.A.P. 9th Cir.)
Issue(s)
Limitations on Avoiding Powers; Perfection of Interest in Property.

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Judge or Jurisdiction information not available
Commercial opinion summary, case decided on November 23, 2021 , LexisNexis #0122-066