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In re Garner

Ruling
Creditor sanctioned for failure to remove payment protection system from debtor's vehicle in violation of stay.
Procedural posture

The chapter 13 debtors filed a motion for sanctions against a creditor for violation of the automatic stay pursuant to 11 U.S.C.S. § 362(k). The debtors alleged that the creditor violated the automatic stay by failing to remove a payment protection system from the debtors' vehicle after a demand was made by the debtors' counsel.

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Consumer opinion summary, case decided on March 09, 2010 , LexisNexis #0510-078

In re Bradsher

Ruling
In state where escrow funds were considered personal property, bank's claim was not secured solely by real property that was debtor's residence and could be modified.
Procedural posture

A bank creditor objected to confirmation of the chapter 13 plan proposed by debtor on the ground that debtor was attempting to modify its secured claim in contravention of the anti- modification provision of 11 U.S.C.S. § 1322(b)(2). The creditor also objected to debtor's $ 22,780 valuation of her residence.

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Consumer opinion summary, case decided on February 16, 2010 , LexisNexis #0410-135

In re Remember Enters.

Ruling
Trustee's application to sell debtor's restaurant equipment granted over objection of creditor.
Procedural posture

A bankruptcy trustee applied for approval to sell a bankruptcy debtor's restaurant equipment to the debtor's principal who would also assume the debtor's rent and utilities obligations for the restaurant property. A creditor which leased another property to the debtor objected to the sale and moved to dismiss the debtor's case on the ground that the proposed sale was solely for the purpose of avoiding successor liability under state law.

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Commercial opinion summary, case decided on February 05, 2010 , LexisNexis #0410-003

Angell v. Williams (In re Williams)

Ruling
Discharge denied due to debtor's failure to keep adequate records and fraudulent intent.
Procedural posture

Adversary plaintiff, the chapter 7 trustee, asserted claims against defendant debtors pursuant to 11 U.S.C.S. § 727(a)(3) and (a)(4)(A), among other grounds, objecting to the debtors' discharge. The trustee claimed that the debtors kept insufficient records, and engaged in a distinct pattern of nondisclosure and false statements showing a reckless indifference for the truth from which fraudulent intent could be inferred.

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Consumer opinion summary, case decided on January 27, 2010 , LexisNexis #0310-093

In re Harrison

Ruling
Chapter 7 case ordered converted to chapter 13 or dismissed for abuse.
Procedural posture

Debtor's chapter 7 case came before the court upon a motion to dismiss pursuant to 11 U.S.C.S. § 707(b) filed by the U.S. Bankruptcy Administrator (hereinafter the Administrator).

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Consumer opinion summary, case decided on January 25, 2010 , LexisNexis #0410-021

In re North End Props. LLC

Ruling
Relief from stay denied as to 29 of 30 properties absent showing of lack of value in excess of indebtedness or that the properties were not necessary for an effective reorganization.
Procedural posture

On December 30, 2009, forty-five separate Motions for Relief From Stay filed by a mortgage company (creditor) came on for hearing, after proper notice. As a consequence of the entry of a Consent Order with regard to 15 properties, there remained for hearing, on December 30, 2009, thirty (30) additional Motions (the Contested Motions).

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Commercial opinion summary, case decided on January 22, 2010 , LexisNexis #0410-044

Saslow v. PRLAP Inc.

Ruling
Trustee could avoid deed of trust on entireties property signed only by one debtor spouse in order to sell the property for benefit of the estate.
Procedural posture

Plaintiff chapter 7 trustee filed an adversary proceeding against defendants, a husband and wife who declared chapter 7 bankruptcy, a bank, and others, seeking a judgment under 11 U.S.C.S. § 544(a) which allowed him to avoid a deed of trust on real property the husband and wife owned, and also allowed him to recover and sell the property for the benefit of the husband and wife's bankruptcy estate. The trustee filed a motion for summary judgment.

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Consumer opinion summary, case decided on January 20, 2010 , LexisNexis #0310-127

In re D&M Land Co. LLC

Ruling
Bank entitled to recover from forfeited earnest money from failed sales of debtor's property.
Procedural posture

Debtor, a land company that had filed a chapter 11, sought a final decree while a bank that was a secured creditor opposed the motion and filed its own motion for disgorgement of certain funds and a turnover of attorneys' fees. Issues included whether certain amounts were properly charged against the bank's interest in certain proceeds pursuant to 11 U.S.C.S. § 506(c) or whether the equitable exception in 11 U.S.C.S. § 552(b)(1) applied.

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Commercial opinion summary, case decided on January 15, 2010 , LexisNexis #0310-116

In re Schofield-Johnson LLC

Ruling
Bad faith dismissal denied where debtor's chapter 11 case was not futile.
Procedural posture

The United States moved to dismiss a chapter 11 debtor's case for lack of good faith pursuant to 11 U.S.C.S. § 1112(b). Alternatively, it moved to lift the automatic stay pursuant to 11 U.S.C.S. § 362(d)(2).

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Commercial opinion summary, case decided on January 13, 2010 , LexisNexis #0310-007

In re Dalton

Ruling
Chapter 13 debtor's discharge denied as prior chapter 7 discharge was received in case converted from chapter 13 and filed less than four years previously.
Procedural posture

The United States Bankruptcy Administrator (BA) filed a motion for an order denying a chapter 13 debtor's discharge on the grounds that she was ineligible for a discharge under 11 U.S.C.S. § 1328(f).

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Consumer opinion summary, case decided on January 07, 2010 , LexisNexis #0210-100