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§ 546

Santiago Rodriguez, In re--Santiago Rodriguez v. Martinez

Ruling
Avoidance of preferential transfer was time barred as the debtors had actual knowledge of alleged preferential transfer no later than 19 days before the closing of their case but failed to bring an avoidance action at that time. (Bankr. D.P.R.)
Issue(s)
Limitations on Avoiding Powers; Statute of Limitations; Time Case is Closed or Dismissed.

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Court :
Consumer opinion summary, case decided on June 08, 2017 , LexisNexis #0717-049

ATP Oil & Gas Corp., In re--Tow v. Bulmahn

Ruling
Trustee's amended avoidance claim dismissed because trustee's diligence alone could notsupport equitable tolling. (Bankr. S.D. Tex.)
Issue(s)
Limitations on Avoiding Powers.

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Commercial opinion summary, case decided on May 16, 2017 , LexisNexis #0617-076

Avila, In re

Ruling
Post-petition retention of debtor's vehicle did not violate automatic stay where a city's continued possession of the vehicle was an act to maintain perfection of its possessory statutory lien. (Bankr. N.D. Ill.)
Issue(s)
Limitations on Avoiding Powers; Perfection of Interest in Property; Nonbankruptcy Law; Maintenance or Continuance.

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Consumer opinion summary, case decided on March 21, 2017 , LexisNexis #0417-107

In re TVGA Eng'g, Surveying, PC

Ruling
Safe harbor does not apply to payee where debtor’s bank was merely a substitute for cash.(Bankr. W.D.N.Y.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Commercial opinion summary, case decided on December 01, 2016 , LexisNexis #0117-019

In re Reichold Holdings US, Inc.

Ruling
Reclamation claim allowed as superior to debtor in possession lender’s lien rights. (Bankr. D.Del.)
Issue(s)
Was reclamation claim subordinate to debtor in possession lender’s lien rights?

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Commercial opinion summary, case decided on August 24, 2016 , LexisNexis #1016-024

FTI Consulting, Inc. v. Merit Mgmt. Grp., LP

Ruling
The safe harbor provision does not protect transfers conducted through a financial institutionas a conduit. (7th Cir.)
Issue(s)
Whether the safe harbor under 11 U.S.C.S. § 546(e) from avoidance of certain transfers by a bankruptcy trustee protected transfers that were simply conducted through financial institutions and other named entities, where the entity was neither the

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:
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on July 28, 2016 , LexisNexis #0816-105

Weisfelner v. Fund 1 (In re Lyondell Chem. Co.)

Ruling
Trustee’s claims against debtor’s former shareholders were covered by the safe harborprovision. (Bankr. S.D.N.Y.)
Issue(s)
Should trustee’s claims against debtor’s former shareholders be stayed or dismissed?

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Commercial opinion summary, case decided on July 20, 2016 , LexisNexis #0816-104

Rentas v. TRM LLC (In re Malavet)

Ruling
Trustee's avoidance proceeding initiated more than two years after entry of order for relief dismissed as time barred.
Issue(s)
Was trustee's avoidance proceeding barred by the statute of limitations?

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Consumer opinion summary, case decided on May 31, 2016 , LexisNexis #0616-094

Kindred v. Gumbinner (In re Innovative Logistics Techniques Inc.)

Ruling
Statute of limitations was tolled for trustee's proceeding to recover assets transferred by corporate debtor to family trust.
Issue(s)
Was trustee's fraudulent transfer proceeding preserved due to equitable tolling of the statute of limitations?

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Commercial opinion summary, case decided on May 31, 2016 , LexisNexis #0616-093

Deutsche Bank Trust Co. Ams. v. Large Private Beneficial Owners (In re Tribune Co. Fraudulent Conveyance Litig.)

Ruling
Transfers were made to financial intermediaries as settlement payments in a securities transaction or is a transfer in connection with a securities contract and were protected from avoidance.
Issue(s)
Whether unsecured creditors are barred by the Bankruptcy Code's automatic stay provision from bringing state law, constructive fraudulent conveyance claims while avoidance proceedings against the same transfers brought by a party exercising the powers of a bankruptcy trustee on an intentional fraud theory are ongoing and, if not, whether the creditors' state law, constructive fraudulent conveyance claims are preempted by section 546(e).

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on March 29, 2016 , LexisNexis #0416-086