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§ 546(a)

Walnut Hill, Inc., In re

Ruling
Motion for extension of deadline to file avoidance actions was denied where Rule 9006(b) didnot apply to § 546(a) and thus it was unnecessary to determine whether cause was shown foran extension of the statutory deadline. (Bankr. D. Conn.)
Issue(s)
Limitations on Avoiding Powers; Statute of Limitations.

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Commercial opinion summary, case decided on June 01, 2018 , LexisNexis #0718-019

Milby, In re--Milby v. Templeton

Ruling
One-year delay in filing fraudulent transfer action after the subject transfers were discovered did not prevent a finding of equitable tolling of the limitations period. (9th Cir.)
Issue(s)
Limitations on Avoiding Powers; Statute of Limitations; Later Than Measurement.

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:
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on November 21, 2017 , LexisNexis #1217-110

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

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

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

Templeton v. Milby (In re Milby)

Ruling
Bankruptcy court erroneously dismissed trustee's fraudulent transfer claims by erroneously finding that trustee's delay in bringing the claims barred application of equitable tolling.
Issue(s)
Whether the bankruptcy court erroneously applied the doctrine of equitable tolling when it granted summary judgment and dismissed the First, Second, and Third Claims for Relief (to the extent they were based on fraudulent transfers alleged in paragraph 30 of the complaint) as untimely under 11 U.S.C.S. § 546(a)(1)(A).

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on February 24, 2016 , LexisNexis #0316-096

Sakhe, In re--Perkins v. North Park Realty Mgmt., LLC

Ruling
Trustee's causes of action were permitted under the statute of limitations they were filedwithin two years of the trustee's appointment. (Bankr. D.N.J.)
Issue(s)
Limitations on Avoiding Powers; Statute of Limitations.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on November 30, 2015 , LexisNexis #0222-034

Boudreaux v. Hall Oil Co. (In re Pope Logging Inc.)

Ruling
Equitable tolling did not apply to statute of limitations that expired prior to conversion to chapter 7 where U.S. Trustee and creditors failed to act timely to pursue claims.
Issue(s)
Was trustee's avoidance proceeding barred by the statute of limitations or did equitable tolling apply?

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Commercial opinion summary, case decided on September 17, 2015 , LexisNexis #1015-052

Firstbank P.R. v. Mender (In re New York Mortg. Bankers Inc.)

Ruling
Trustee's late-filed preference counterclaim against creditor dismissed as time-barred.
Issue(s)
Was trustee's counterclaim against creditor alleging that its mortgage notes were avoidable preferences time barred?

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Commercial opinion summary, case decided on April 13, 2015 , LexisNexis #0515-017

Colon v. Wright (In re Wright)

Ruling
Trustee's proceeding to recover transfers made prior to conversion from chapter 11 to chapter 7 dismissed as time-barred.
Issue(s)
Should trustee's proceeding to avoid transfers made prior to conversion from chapter 11 to chapter 7 be dismissed?

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Consumer opinion summary, case decided on March 09, 2015 , LexisNexis #0515-126