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southern district of alabama

In re Gibson

Ruling
Estate of non-debtor spouse was not entitled to administrative expense claim for fees paid on condominium after fraudulent transferred of debtor's interest until the unit was reconveyed to debtor.
Issue(s)
Was estate of non-debtor spouse was entitled to an administrative expense claim for fees paid on a condominium where debtor fraudulently transferred her interest in the unit to the couple's son?

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Consumer opinion summary, case decided on June 12, 2014 , LexisNexis #0714-077

Schuller v. Ocwen Loan Servicing LLC (In re Schuller)

Ruling
Reference of debtor's Fair Debt Collection Practices Act cause of action withdrawn.
Issue(s)
Should bankruptcy court withdraw reference of postdischarge action by debtors under the Fair Debt Collection Practices Act?

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Consumer opinion summary, case decided on February 05, 2014 , LexisNexis #0314-135

In re Willis

Ruling
Debtor's divorce obligation to second spouse for making debtor's child support payments to debtor's first spouse was not a nondischargeable domestic support obligation.
Issue(s)
Was debt owed by debtor to second spouse pursuant to divorce decree as a result of the second spouse making payments on debtor's child support obligation to debtor's first spouse a nondischargeable domestic support obligation.

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Consumer opinion summary, case decided on January 21, 2014 , LexisNexis #0214-056

Pilot v. Alesco Preferred Funding XV Ltd. (In re First Baldwin Bancshares Inc.)

Ruling
Subordination agreement in favor of special purpose entity allowed.
Issue(s)
Was subordination agreement contained in note enforceable in favor of special purpose entity.

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Commercial opinion summary, case decided on September 30, 2013 , LexisNexis #1013-081

In re Bradley

Ruling
Student loan debt could constitute "special circumstances" to rebut presumption of abuse.
Issue(s)
Could debtors cite student loan obligations as "special circumstances" in order to rebut the presumption of abuse.

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Consumer opinion summary, case decided on August 30, 2013 , LexisNexis #0913-125

Andrews v. RBL LLC (In re Vista Bella Inc.)

Ruling
Assignment of note and mortgage was not an avoidable transfer due to debtor's retention of interest.
Issue(s)
On reconsideration, should assignments of condominium purchase agreements be held to be avoidable transfers.

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Commercial opinion summary, case decided on August 09, 2013 , LexisNexis #0913-022

In re Rattler

Ruling
Administrative expense claim allowed for debtor's postpetition rental arrearage.
Procedural posture

Debtor's chapter 13 matter was before the court pursuant to a creditor's Motion to Allow Administrative Claim related to debtor's failure to meet her obligations to pay rent under a post-petition residential lease.

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Consumer opinion summary, case decided on March 06, 2013 , LexisNexis #0313-112

Brannon v. Chuck Stevens Auto Inc.

Ruling
Creditor that received at least oral notice could not dismiss proceeding for stay violation.
Procedural posture

Plaintiff debtor brought an adversary proceeding against defendant creditor, an auto dealer, asserting that creditor, through an agent, willfully violated the automatic stay by harassing her despite actual knowledge of her bankruptcy filing, pursuant to 11 U.S.C.S. § 362(k). Creditor moved to dismiss the complaint, denying it had received formal notice of the bankruptcy filing.

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Consumer opinion summary, case decided on January 22, 2013 , LexisNexis #0213-042

Brannan v. Wells Fargo Home Mortg. (In re Brannan)

Ruling
Class certification granted for plaintiff debtor mortgagees with fraud claims against lender for false affidavits filed in stay proceedings.
Procedural posture

Putative class plaintiffs, debtor-mortgagors who alleged that defendant lender filed, or caused to be filed, false affidavits in support of motions for relief from automatic stay. The debtors requested that two classes of plaintiffs be certified by the court pursuant to Fed. R. Bankr. P. 7023.

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Consumer opinion summary, case decided on January 08, 2013 , LexisNexis #0113-140

In re Crenshaw

Ruling
Relief from stay to pursue state court remedies granted given lack of equity in property that was not necessary for reorganization.
Procedural posture

Creditors filed a motion for relief from the automatic stay under 11 U.S.C.S. § 362(d)(2) in order to pursue state law remedies with regard to their lien on the debtor's property.

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Consumer opinion summary, case decided on November 08, 2012 , LexisNexis #1212-005