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judge leonard

In re Rogers

Ruling
Unsecured deficiency claim arising from post-discharge default foreclosure was discharged in debtor's case.
Procedural posture

A credit union filed a motion seeking a determination that the discharge granted to the chapter 13 debtors did not extinguish their liability for a deficiency arising from a post- discharge default and foreclosure sale. The debtors asserted that the deficiency was not excepted from discharge under 11 U.S.C.S. §§ 1328(a), 1322(b)(5), and 1322(b)(2).

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Consumer opinion summary, case decided on July 08, 2013 , LexisNexis #0813-031

Sea Horse Realty & Constr. Inc. v. CitiMortgage Inc. (In re Sea Horse Realty & Constr. Inc.)

Ruling
Stay pending appeal granted to prevent distribution of proceeds of sale of property pursuant to deed of trust disputed by debtor.
Procedural posture

Creditor filed a motion for a stay pending appeal of two orders pursuant to Fed. R. Bankr. P. 8005

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Commercial opinion summary, case decided on June 17, 2013 , LexisNexis #0713-104

In re Tosh

Ruling
Debtor's counsel's application for compensation denied because counsel's employment had not been authorized.
Procedural posture

Debtor's chapter 11 plan of reorganization was confirmed. Counsel filed an application for employment nunc pro tunc. While his application for employment was pending, counsel filed an application for compensation for services provided and expenses incurred as counsel for the debtor. The bankruptcy administrator objected to the application. The court entered an order denying counsel's application for employment nunc pro tunc.

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Consumer opinion summary, case decided on June 11, 2013 , LexisNexis #0713-002

Butler v. Johnson (In re Johnson)

Ruling
Unintentional misstatements and omissions by illiterate debtor were not grounds for denial of discharge.
Procedural posture

Debtor filed a voluntary petition for relief under chapter 7 of the Bankruptcy Code. Trustee initiated an adversary proceeding against the debtor, seeking denial of his discharge pursuant to 11 U.S.C.S. § 727(a)(2), (a)(3), and (a)(4)(A). The trustee moved for summary judgment. The trustee also filed a motion seeking an order declaring the requests for admission be deemed admitted for purposes of his summary judgment motion.

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Consumer opinion summary, case decided on June 04, 2013 , LexisNexis #0613-131

In re Tosh

Ruling
Attorney's nunc pro tunc motion for approval of employment denied due to unreasonable delay.
Procedural posture

The chapter 11 debtor's counsel filed an application for nunc pro tunc approval of his employment under 11 U.S.C.S. § 327. He sought relief on the grounds of excusable neglect.

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Consumer opinion summary, case decided on May 21, 2013 , LexisNexis #0713-073

Bolton v. Jacobson (In re Province Grande Olde Liberty LLC)

Ruling
Relief from stay and motion for abstention granted to allow state court to adjudicate action arising out of alleged Ponzi scheme.
Procedural posture

Investors filed a state court action against debtor and others arising from an alleged Ponzi scheme. The investors sought relief from the automatic stay under 11 U.S.C.S. § 362(d)(1) and mandatory abstention and remand to the state court under 28 U.S.C.S. § 1334(c)(2).

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Commercial opinion summary, case decided on May 17, 2013 , LexisNexis #0613-078

In re Ecast Corp.

Ruling
Motion to compel cure payment under license agreement denied as not entitled to priority over other administrative expense claims.
Procedural posture

In a bankruptcy case, a creditor filed a motion to compel a cure payment called for under a license agreement executed by the creditor and the debtor. The motion was opposed by the bankruptcy trustee.

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Commercial opinion summary, case decided on May 16, 2013 , LexisNexis #0613-082

In re Holzapfel

Ruling
Debtor's pending state court action arising out of 1977 stock purchase and commenced more than 10 years after case was closed could be abandoned.
Procedural posture

A debtor filed an amended motion for entry of an order directing a chapter 7 trustee to abandon certain property of the estate, a pending state court action, pursuant to 11 U.S.C.S. § 554. The defendant in the state court case objected to the motion.

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Consumer opinion summary, case decided on May 15, 2013 , LexisNexis #0613-035

In re Johnston

Ruling
Relief from stay granted as to state court action from which bankruptcy court abstained.
Procedural posture

Plaintiff moved for relief from the automatic stay, to which debtor objected. Also before the court were plaintiff's motions for abstention, permissive or mandatory, and for remand to the Superior Court of New Hanover County, North Carolina pursuant to 28 U.S.C.S. §§ 1334(c), 1447 (c) and 1452(b).

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Consumer opinion summary, case decided on May 02, 2013 , LexisNexis #0513-110

Angell v. Meherrin Agric. & Chem. Co. (In re Tanglewood Farms Inc.)

Ruling
Chapter 7 trustee could not avoid preconversion transfers made by debtor while a chapter 11 debtor in possession.
Procedural posture

Chapter 7 trustee filed an adversary proceeding against defendant creditor, seeking a determination that he was allowed under 11 U.S.C.S. §§ 544, 547-551, and N.C. Gen. Stat. § 39- 23.1 et seq. to avoid transfers a corporation ("debtor") made to the creditor while the debtor was in chapter 11 bankruptcy. The creditor filed a motion to dismiss.

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Commercial opinion summary, case decided on May 01, 2013 , LexisNexis #0513-125