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In re Neclerio

Ruling
Plan that did not provide 100% distribution to unsecured creditors despite ability to pay denied.
Procedural posture

The debtor filed for relief under chapter 13 of the Bankruptcy Code, and filed a first amended chapter 13 plan. The debtor sought confirmation of the first amended plan.

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Consumer opinion summary, case decided on August 20, 2008 , LexisNexis #0908-125

Carlo v. Orion Omniservice Co. (In re Carlo)

Ruling
Notice requirements for due process must be balanced with expeditiousness of bankruptcy proceedings.
Procedural posture

Plaintiff debtor filed a complaint against defendant creditor to determine the dischargeability of a debt. Pursuant to Fed. R. Bankr. P. 7055(a), the debtor moved for default. The issue was whether Fed. R. Bankr. 7004(b)(3) required service addressed to the attention of an individual by name and office title, or simply by office title.

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Consumer opinion summary, case decided on August 15, 2008 , LexisNexis #1208-104

In re Casavalencia

Ruling
Case dismissed as filed for improper purpose to evade responsibility for securities fraud scheme and debtor's attorney sanctioned for filing without reasonable inquiry.
Procedural posture

Four creditors of the debtor moved to dismiss his case as a bad faith chapter 13 filing, for relief from the automatic stay so that they may continue with prepetition litigation against the debtor, and for the award of attorneys' fees and costs.

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Consumer opinion summary, case decided on June 05, 2008 , LexisNexis #0708-055

In re Bryer

Ruling
Non-appearing creditor and collection agency fined for violation of discharge injunction.
Procedural posture

The court considered an order to show cause why an assignee creditor of the debtor and its collection agency should not be held in contempt for violating the discharge injunction of 11 U.S.C.S. § 524. Both entities were directed to appear and explain why they had engaged in violative conduct, under the court's inherent powers and its statutory authority under 11 U.S.C.S. § 105(a).

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Consumer opinion summary, case decided on April 24, 2008 , LexisNexis #0608-009

Kapila v. United States (In re Taylor)

Ruling
Debtor's irrevocable waiver of net operating loss carryback avoided as constructively fraudulent transfer.
Procedural posture

Plaintiff chapter 7 trustee filed a Fed. R. Civ. P. 56 motion for summary judgment and defendant United States Government filed a cross motion for summary judgment on an adversary proceeding to avoid and recover the debtor's election of an irrevocable waiver of a prepetition net operating loss (NOL) carryback under the Internal Revenue Code as a constructively fraudulent transfer, pursuant to 11 U.S.C.S. §§ 548 and 550.

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Consumer opinion summary, case decided on April 10, 2008 , LexisNexis #0508-014

Kapila v. United States (In re Taylor)

Ruling
Irrevocable waiver of prepetition net operating loss carryback was a constructively fraudulent transfer.
Procedural posture

Plaintiff chapter 7 trustee filed a Fed. R. Civ. P. 56 motion for summary judgment and defendant United States Government filed a cross motion for summary judgment on an adversary proceeding to avoid and recover the debtor's election of an irrevocable waiver of a prepetition net operating loss (NOL) carryback under the Internal Revenue Code as a constructively fraudulent transfer, pursuant to 11 U.S.C.S. §§ 548 and 550.

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Consumer opinion summary, case decided on April 10, 2008 , LexisNexis #0508-119

Western Union Fin. Servs. v. Mascarenhas (In re Mascarenhas)

Ruling
Dischargeability proceeding dismissed as filed one day after expiration of 60-day deadline.
Procedural posture

Plaintiff creditors filed an adversary proceeding against defendant debtor objecting to the dischargeability of an obligation pursuant to 11 U.S.C.S. § 523. The debtor filed a motion to dismiss, claiming that the adversary proceeding was not timely, pursuant to Fed. R. Bankr. P. 4007(c).

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Consumer opinion summary, case decided on February 26, 2008 , LexisNexis #0408-065

In re Patriot Aviation Servs.

Ruling
Law firm representing itself not entitled to administrative claim for fees.
Procedural posture

A law firm filed an application seeking allowance of $ 26,335 for legal fees as an administrative expense pursuant to 11 U.S.C.S. § 503(b)(3)(D) and (b)(4).

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Commercial opinion summary, case decided on February 21, 2008 , LexisNexis #0408-042

In re Bryan Road LLC

Ruling
Prepetition agreement waving stay in event of bankruptcy was enforceable.
Procedural posture

A secured creditor of a chapter 7 debtor filed a motion for stay relief pursuant to 11 U.S.C.S. § 362, based upon a pre-petition consent to stay relief signed by the debtor.

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Commercial opinion summary, case decided on February 12, 2008 , LexisNexis #0308-108

In re SunCruz Casinos LLC

Ruling
Late filed personal injury claim allowed where prejudice to debtor was outweighed by right to pursue claim.
Procedural posture

The debtor filed for relief under chapter 11. A former employee filed a motion for rehearing on the court's earlier order denying the judgment creditor's motion to allow a late- filed claim and to allow relief from stay. The debtor and the primary secured creditor objected to the motion.

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Commercial opinion summary, case decided on October 26, 2007 , LexisNexis #1107-139