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In re Grullon

Ruling
Bad faith dismissal denied as debtor's actions were not sufficiently egregious.
Issue(s)
Did debtor's actions in failing to make candid and full disclosure of assets and financial affairs amount to bad faith that would warrant dismissal?

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Consumer opinion summary, case decided on May 20, 2014 , LexisNexis #0614-062

Harrison v. New Jersey Cmty. Bank (In re Jesup & Lamont Inc.)

Ruling
Preference period transfer at direction of debtor's parent corporation to satisfy debt of parent was avoidable.
Issue(s)
Was the collateralization of a debt for the benefit of debtor's parent, shortly before the bankruptcy filings of both the parent and the subsidiary, avoidable as a fraudulent conveyance because the debtor received no consideration or as a preferential transfer to satisfy an antecedent debt?

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Commercial opinion summary, case decided on March 26, 2014 , LexisNexis #0414-059

In re Quad-C Funding LLC

Ruling
Motion to dismiss for lack of authority to file petition denied.
Issue(s)
Whether debtor's chapter 11 petition should be dismissed pursuant to 11 U.S.C.S. § 1112(b) on motion of a member of the debtor limited liability company (LLC) and over objection of the debtor and a creditor.

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Commercial opinion summary, case decided on August 16, 2013 , LexisNexis #0913-059

In re Stillwater Asset Backed Offshore Fund Ltd.

Ruling
Dismissal of involuntary petition denied where ineffective distribution in kind did not satisfy debts of petitioning creditors or create a bona fide dispute.
Procedural posture

Petitioning creditors filed an involuntary chapter 11 case against the alleged debtor. The alleged debtor contested the involuntary petition, seeking an order, pursuant to 11 U.S.C.S. §§ 105(a), 303, and 305, (i) dismissing the petition, (ii) imposing sanctions against the petitioning creditors, and (iii) scheduling a damages hearing and directing the petitioning creditors to post a bond pending such hearing.

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Commercial opinion summary, case decided on January 17, 2013 , LexisNexis #0213-038

In re Gerova Fin. Group

Ruling
Recognition of foreign main proceeding granted and could not be conditioned on cost-benefit analysis, approval of creditors or examination of need for proceedings.
Procedural posture

Liquidators of debtors in foreign insolvency proceedings petitioned a bankruptcy court for recognition of the foreign proceedings as foreign main proceedings. Creditors of the debtors objected to recognition on the grounds that recognition was unnecessary and against U.S. public policy.

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Commercial opinion summary, case decided on October 22, 2012 , LexisNexis #1112-066

In re DeWitt Rehab. & Nursing Ctr. Inc.

Ruling
Claim for third party payments to employee benefit plan not maintained by debtor was a general unsecured claim.
Procedural posture

A staffing service contended that a portion of its claim was entitled to priority status under 11 U.S.C.S. § 507(a)(5) as contributions to an employee benefit plan. The chapter 11 debtor filed a motion to expunge the priority portion of the claimant's proof of claim.

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Commercial opinion summary, case decided on August 17, 2012 , LexisNexis #0912-043

In re Cabrini Med. Ctr.

Ruling
Relief from stay to proceed against entity that allegedly controlled debtor on alter ego theory denied.
Procedural posture

Four of the debtor's creditors request that the automatic stay be lifted in order to allow them to name the debtor as a defendant in a state-court action seeking recovery from an entity that allegedly controlled the debtor.

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Commercial opinion summary, case decided on June 15, 2012 , LexisNexis #0712-086

In re Eastman Kodak Co.

Ruling
Adversary proceeding was necessary to effect sale of debtor's patents free and clear of claimed interests of other companies.
Procedural posture

Chapter 11 debtors asked the court to issue an order per 11 U.S.C.S. § 105 in aid of their planned sale of certain patents to the effect that two affiliated companies had no ownership interests in any of the patents and permitting a sale of the patents to third parties free and clear of such claims. At issue was whether § 105 authorized such an order and the effect, if any, of Fed. R. Bankr. P. 7001 and 11 U.S.C.S. § 363.

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Commercial opinion summary, case decided on June 15, 2012 , LexisNexis #0712-072

In re Lear Corp.

Ruling
Antitrust action enjoined to the extent arising prior to effective date of debtor's plan.
Procedural posture

Reorganized debtors filed a motion requesting entry of an order (i) enforcing the discharge provisions of their joint plan of reorganization and (ii) directing dismissal of antitrust litigation recently commenced against them by a purported class of parties who claimed to be indirect purchasers of one of the debtors' products.

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Commercial opinion summary, case decided on February 10, 2012 , LexisNexis #0312-061

Tronox Inc. v. Anadarko Petroleum Corp. (In re Tronox Inc.)

Ruling
Debtor's recovery on fraudulent transfer claims was not capped by §550(a).
Procedural posture

Chapter 11 debtor filed a complaint seeking to establish that a transfer of assets in a spin-off was an intentional or constructive fraudulent conveyance under 11 U.S.C.S. §§ 548 or 544(b). Both parties moved for partial summary judgment. Defendant transferee sought a ruling that 11 U.S.C.S. § 550 capped the debtor's recovery on its claims at the amount of unpaid creditor claims. The debtor sought a ruling that § 550 imposed no cap.

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Commercial opinion summary, case decided on January 20, 2012 , LexisNexis #0212-058