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§ 1412

In re Caesars Entmt Operating Co.

Ruling
Voluntary case filed by debtor in one state should proceed rather than prior involuntary case in another state where the debtor's venue would better support reorganization.
Issue(s)
Was the proper venue for debtors' bankruptcy the district in which the debtor was incorporated and where petitioning creditors initiated an involuntary bankruptcy proceeding or the district where the debtor and certain of its affiliates initiated a voluntary bankruptcy proceeding three days later?

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Commercial opinion summary, case decided on February 02, 2015 , LexisNexis #0215-138

City & Borough of Juneau v. Beardsley (In re Fountain Vill. Dev.)

Ruling
City's state court action removed to a bankruptcy court transferred to the court where debtor's case was originally filed.
Issue(s)
Should removed state court action by city and borough against debtor be transferred to bankruptcy court where debtor originally filed its case?

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Commercial opinion summary, case decided on September 16, 2014 , LexisNexis #1014-104

Smith v. Quiznos Master LLC (In re Bouley)

Ruling
Trustee's proceeding against debtor's franchisors transferred to state with significant relationship to underlying agreement.
Issue(s)
Should trustee's proceeding against debtor's franchisors be dismissed or transferred to venue specified in franchise agreement?

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Consumer opinion summary, case decided on November 27, 2013 , LexisNexis #1213-101

Construction Date Solutions LLC v. Grant (In re Grant)

Ruling
Transfer of venue denied where forum non conveniens was not established.
Issue(s)
Should venue of adversary proceeding be changed to district where debtor formerly lived and conducted business with creditor.

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Consumer opinion summary, case decided on August 19, 2013 , LexisNexis #0913-136

In re Municipal Corr. LLC

Ruling
Venue transferred where only connection to filing district was location of debtor's incorporation.
Procedural posture

In this chapter 11 case, a creditor filed a motion to transfer venue under 28 U.S.C.S. § 1412 from the District of Nevada to the Middle District of Georgia.

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Commercial opinion summary, case decided on December 28, 2012 , LexisNexis #0113-097

In re Honeycutt

Ruling
Transfer of venue denied where debtor's principal place of business was within district.
Procedural posture

Debtor's ex-spouse, the largest unsecured creditor in the case, filed a motion contending that venue was improper in the Eastern District of North Carolina pursuant to 28 U.S.C.S. §§ 1408, 1406, and sought an order transferring the case to the Western District of North Carolina, or dismissal pursuant to Fed. R. Bankr. P. 1014(a)(2). If venue was proper, she maintained the case should be transferred pursuant to 28 U.S.C.S. § 1412. Debtor objected.

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Consumer opinion summary, case decided on December 21, 2012 , LexisNexis #0113-061

In re Boerderji de Veldhoek LLC

Ruling
Venue changed to district where debtor's dairy farm was located.
Procedural posture

Debtors, an LLC and two individuals, filed separate cases under chapter 12 of the Bankruptcy Code in the Northern District of New York, and a bank that held claims against the debtors' bankruptcy estates filed a motion to change the venue of both cases to the Northern District of Iowa or, in the alternative, for relief from the automatic stay. The debtors opposed the bank's motion.

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Commercial opinion summary, case decided on October 25, 2012 , LexisNexis #1112-138

In re Lucas

Ruling
Venue transferred to district where most of creditors were located.
Procedural posture

Creditors, invoking 28 U.S.C.S. § 1404(a) and 28 U.S.C.S. § 1412, sought to transfer venue in debtor's chapter 11 case from the within district (District 1), which was the situs of debtor's residence and his current business ventures, to a different district (District 2), alleged to be the situs of most of debtor's creditors and of a dispute underlying movants' state court suit against debtor. Debtor opposed transfer on various grounds.

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Consumer opinion summary, case decided on October 19, 2012 , LexisNexis #1112-139

Apperson v. Old Fort Banking Co. (In re Batt)

Ruling
Venue of adversary proceeding transferred to district where debtor, creditors and witnesses resided and local law controlled for convenience of parties.
Procedural posture

Chapter 11 trustee filed a complaint against defendant creditors seeking, inter alia, to recover alleged preferences, fraudulently conveyed property, and post-petition transfers. The creditors each filed a motion to transfer venue from the Western District of Kentucky to the Northern District of Ohio pursuant to 28 U.S.C.S. § 1412 and Fed. R. Bankr. P. 7087. The trustee opposed the motions.

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Consumer opinion summary, case decided on October 05, 2012 , LexisNexis #1112-033

In re Silicon Valley Innovation Co.

Ruling
Transfer of venue to district where debtor was domiciled due to failure to maintain office in current district within 180 days of petition date.
Procedural posture

Movant creditor sought to dismiss the chapter 11 bankruptcy case of debtor, pursuant to 11 U.S.C.S. §§ 305(a) and 1112(b), or, alternatively, to dismiss or transfer the case due to improper venue. The debtor also moved to convert its chapter 11 case to a chapter 7 case.

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Commercial opinion summary, case decided on August 30, 2012 , LexisNexis #1012-102