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Rosenberg v. DVI Receivables XIV LLC (In re Rosenberg)

Ruling
Involuntary debtor's state law claims against petitioning creditors were preempted by § 303(i).
Procedural posture

Plaintiff putative chapter 7 debtor filed a complaint against defendants, petitioning creditors and banks, for attorney's fees, costs, and damages pursuant to 11 U.S.C.S. §§ 303(i) and 105. In addition, he sought to recover damages based on state law claims of abuse of process and malicious prosecution and state law theories of recovery such as respondeat superior. The petitioning creditors and banks moved to dismiss the complaint.

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Consumer opinion summary, case decided on March 23, 2012 , LexisNexis #0412-072

8699 Biscayne LLC v. Indigo Real Estate LLC (In re 8699 Biscayne LLC)

Ruling
Fraudulent transfer claim failed where debtor received reasonably equivalent value.
Procedural posture

Adversary plaintiff debtor in possession brought a claim against defendant creditors, alleging fraudulent transfers in violation of 11 U.S.C.S. § 548(a) and Fla. Stat. Ann. § 726.105(1)(b). The creditors moved for summary judgment on that cause of action. Various creditors had loaned the debtor $4,247,150 to be secured by the debtor's real property.

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Commercial opinion summary, case decided on March 22, 2012 , LexisNexis #0412-090

In re Fisher Island Invs. Inc.

Ruling
Dismissal of appeal vacated as Rule 8002 applied to all party appellants and appeal was timely filed.
Procedural posture

After the court dismissed an appeal as untimely under Fed. R. Bankr. P. 8002, the dismissed appellant requested reconsideration of the dismissal.

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Commercial opinion summary, case decided on March 16, 2012 , LexisNexis #0412-104

In re Luban

Ruling
Confirmation denied on trustee's objection given failure to commit all projected disposable income to plan.
Procedural posture

Debtors' case came before the court upon the chapter 13 trustee's Notice of Deficiency for Confirmation.

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Consumer opinion summary, case decided on February 27, 2012 , LexisNexis #0412-033

In re Sanchez-Villalba

Ruling
Plan ordered amended to include one quarter equity interest in property held by debtor.
Procedural posture

This cause came before the court for hearing upon the trustee's objection to confirmation of debtor's plan, based on the assertion that debtor owned 1/4 of certain real properties and therefore the value of 1/4 of the properties should be included in debtor's estate under 11 U.S.C.S. § 541.

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Consumer opinion summary, case decided on February 23, 2012 , LexisNexis #0312-130

Dillworth v. Pichardo (In re Pichardo)

Ruling
Trustee's adversary proceeding dismissed to the extent seeking to avoid fraudulent and preferential transfers as not brought within two year limitations period.
Procedural posture

After chapter 7 trustee commenced an adversary proceeding objecting to the debtor's discharge, objecting to his claimed exemptions, and seeking recovery of fraudulent and preferential transfers, defendants, the debtor and his non-debtor spouse, filed a motion to dismiss under 11 U.S.C.S. § 546. The debtor, individually, also filed a motion to dismiss.

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Consumer opinion summary, case decided on January 31, 2012 , LexisNexis #0312-051

In re Harbour East Dev. Ltd.

Ruling
Single asset real estate debtor's motion for recovery of maintenance and preservation expenses for condominium units denied.
Procedural posture

A chapter 11 debtor filed a motion for an order authorizing the use of cash collateral under 11 U.S.C.S. § 363(c)(2) and authorizing the recovery of maintenance and preservation expenses from property securing allowed claims pursuant to 11 U.S.C.S. § 506(c). It filed a supplemental motion for an order authorizing the use of cash collateral to obtain a supersedeas bond. A creditor that was the first-priority mortgage holder objected.

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Commercial opinion summary, case decided on December 05, 2011 , LexisNexis #0112-082

In re JR Mortgs. Inc.

Ruling
Foreclosure sale did not violate stay as debtor had no interest in property after prepetition judgment.
Procedural posture

Debtor, a corporation that had filed a chapter 7 case that had been closed due to debtor's failure to comply with certain requirements, moved to reopen the case in order to pursue sanctions against a creditor that it claimed to have willfully violated the automatic stay in 11 U.S.C.S. § 362. An affiliated person also sought other relief.

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Commercial opinion summary, case decided on December 05, 2011 , LexisNexis #0112-075

In re Case C&C Dev. Group LLC

Ruling
Appointment of interim trustee in involuntary case denied due to failure to show wasting of property.
Procedural posture

A petitioning creditor filed a motion to appoint an interim trustee pursuant to 11 U.S.C.S. § 303(g) or to enjoin an alleged debtor from disposing or encumbering estate property.

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Commercial opinion summary, case decided on November 15, 2011 , LexisNexis #0112-002

In re Sarhan

Ruling
Relief from stay granted to allow guardian for debtor's deceased mother to obtain order from probate court quantifying sanctions against debtor.
Procedural posture

The guardian for the now-deceased mother of debtor sought termination of the automatic stay in 11 U.S.C.S. § 362 to pursue a ruling from a state probate court quantifying the monetary sanctions to be awarded against debtor based on the state court's finding that debtor had improperly pursued frivolous claims.

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Consumer opinion summary, case decided on November 15, 2011 , LexisNexis #0112-009