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In re Atlas Shipping AS

Ruling
Maritime attachments obtained against foreign debtor could be vacated and garnished funds turned over to foreign representative.
Procedural posture

Petitioner foreign representative filed an action under chapter 15 of the Bankruptcy Code, seeking recognition of a bankruptcy action that was filed by debtors, two Danish corporations, in Denmark. The foreign representative asked the court to vacate nine maritime attachments which creditors had obtained, pursuant to Supp. R. Adm. or Mar. Cl. & Asset Forfeiture Actions B, in the District Court for the Southern District of New York.

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Commercial opinion summary, case decided on April 27, 2009 , LexisNexis #0609-024

In re Giggsby

Ruling
Court refused to reinstate stay in case filed solely to thwart eviction.
Procedural posture

Debtor filed a petition under chapter 13 of the Bankruptcy Code, and a landlord filed a motion to vacate the stay that was imposed when the debtor declared bankruptcy so it could execute a warrant of eviction it obtained in state court. The court granted the landlord's motion and sustained the landlord's objection to a certification the debtor filed under 11 U.S.C.S. § 362(l)(1). The debtor filed an application for an order reinstating the stay.

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Consumer opinion summary, case decided on April 17, 2009 , LexisNexis #0609-005

In re Stansbury

Ruling
Post-confirmation unsecured claim filed by bank against property surrendered by debtor disallowed.
Procedural posture

The debtors filed for relief under chapter 13 of the Bankruptcy Code and a bank filed a claim in the bankruptcy proceedings. The debtors filed an objection to the claim.

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Consumer opinion summary, case decided on March 09, 2009 , LexisNexis #0609-128

In re Morrison

Ruling
Life insurance proceeds received more than 180 days postpetition were not property of the estate.
Procedural posture

The debtors, a husband and a wife, filed for relief under chapter 13 of the Bankruptcy Code and a plan was confirmed. In October 2007, the matter was converted to a proceeding under chapter 7. A chapter 7 trustee filed a motion for turn over of a life insurance policy proceeds to the estate, which was granted. The debtor wife filed a motion for rehearing of the turnover property.

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Consumer opinion summary, case decided on March 02, 2009 , LexisNexis #0609-121

In re BH S&B Holdings LLC

Ruling
Costs of removal of postpetition, prerejection liens were administrative expense claims.
Procedural posture

Debtor businesses filed petitions under chapter 11 of the Bankruptcy Code and continued to operate two stores that were located on real property that was owned by a landlord. The landlord filed a motion for an order requiring the debtors to perform postpetition lease obligations, pursuant to 11 U.S.C.S. § 365(d)(3), with respect to mechanics' liens that had been placed on its property. The debtors opposed the motion.

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Commercial opinion summary, case decided on February 10, 2009 , LexisNexis #0309-077

Newman v. United States (In re Newman)

Ruling
Government's attempts to collect nondischargeable tax debt did not violate discharge injunction.
Procedural posture

Plaintiff bankruptcy debtor brought an adversary proceeding against defendant United States alleging that the government violated the discharge injunction of 11 U.S.C.S. § 524(a) by attempting to collect additional tax liabilities after the debtor provided for and paid taxes for the tax years in question under the debtor's confirmed chapter 11 plan. The government moved for summary judgment.

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Consumer opinion summary, case decided on November 25, 2008 , LexisNexis #0309-032

Wharton v. Shiver (In re Shiver)

Ruling
State default judgment in fraud case was "fully litigated" and determinative of nondischargeability of debt.
Procedural posture

Plaintiffs, creditors, filed an adversary proceeding against defendant debtor seeking a determination that their debt was nondischargeable under 11 U.S.C.S. § 523(a)(2)(A). The creditors had obtained a Florida state court default judgment for fraud and contended that the full faith and credit statute, 28 U.S.C.S. § 1738, required that the Florida fraud judgment be given preclusive effect. The parties filed cross-motions for summary judgment.

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Consumer opinion summary, case decided on November 05, 2008 , LexisNexis #1208-080

In re Shihai

Ruling
Fee application of debtor's pre-conversion counsel treated as interim application pending full administration.
Procedural posture

Counsel for the debtors filed a first and final application for fees and expenses. The United States Trustee and chapter 7 trustee opposed the application.

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Consumer opinion summary, case decided on August 18, 2008 , LexisNexis #0908-009

In re Vinieris

Ruling
Secured judgment that was still valid after more than twenty years was in excess of chapter 13 debt limits, disqualifying debtor.
Procedural posture

Movant creditor sought dismissal of a chapter 13 on the basis that it was a judgment creditor with a secured claim against debtor exceeding $9.9 million, rendering debtor ineligible to file a chapter 13 due to 11 U.S.C.S. § 109(e). Debtor opposed the motion on the ground that movant was no longer a judgment creditor by reason of the age of the underlying judgment. The status of the debt under state law including N.Y. C.P.L.R. § 5014 was at issue.

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Consumer opinion summary, case decided on August 07, 2008 , LexisNexis #0808-107

In re Kwabena Osei

Ruling
Debtor entitled to full rental expense deduction of IRS Local Standards rather than lower actual expense.
Procedural posture

A creditor objected to confirmation of debtor's chapter 13 plan on the ground that debtor, in calculating disposable income, deducted the full amount allowed under the IRS Local Standards for mortgage/rental expense even though debtor's actual monthly rental expense was lower. At issue was the proper interpretation of 11 U.S.C.S. § 1325(b)(3) and 11 U.S.C.S. § 707(b)(2)(A)(ii)(I) both individually and in the context of the IRS Local Standards.

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Consumer opinion summary, case decided on June 25, 2008 , LexisNexis #0708-127