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western district of north carolina

Campbell v. Hanover Ins. Co.

Ruling
Bankruptcy court did not err in upholding creditor's earmarking defense to preference proceeding.
Procedural posture

Appellant Chapter 11 trustee challenged a decision of the U.S. Bankruptcy Court for the Western District of North Carolina, which granted summary judgment to appellee in the trustee's action seeking to avoid a preferential transfer pursuant to 11 U.S.C.S. § 547.

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Consumer opinion summary, case decided on September 22, 2011 , LexisNexis #1011-096

In re Sullivan

Ruling
Manual changes to debtor's schedules by attorney were not grounds for sanctions absent fraud or improper action.
Procedural posture

The United States Bankruptcy Administrator filed a motion for sanctions against the debtor's attorney on account of manual changes the attorney made to the Official Form 22A-- Chapter 7 Statement of Current Monthly income and Means-Test Calculation.

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Consumer opinion summary, case decided on August 24, 2011 , LexisNexis #0911-103

In re Woodend LLC

Ruling
Case dismissed where debtor LLC acquired another LLC just prior to petition date in order to avoid foreclosure on acquired LLC's property.
Procedural posture

Debtor, a South Carolina limited liability company ("LLC"), filed a petition under chapter 11 of the Bankruptcy Code and operated its business as a debtor in possession. A bank that held a secured interest in property the debtor acquired when it merged with another South Carolina LLC shortly before it declared bankruptcy filed a motion to dismiss the debtor's case pursuant to 11 U.S.C.S. § 1112, claiming that the case was filed in bad faith.

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Commercial opinion summary, case decided on August 24, 2011 , LexisNexis #0911-131

In re Prosperity Park LLC

Ruling
Relief from stay to proceed against debtor's property granted where debtor's chapter 11 plan could not be confirmed.
Procedural posture

In a Chapter 11 bankruptcy case, a debtor filed a motion seeking to confirm its first amended disclosure statement and plan of reorganization. A bank filed a motion seeking relief from the automatic stay.

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Commercial opinion summary, case decided on May 17, 2011 , LexisNexis #0611-042

In re Thams

Ruling
Trustee's lien rights in debtor's vehicle were superior to those of co-debtor who held no legal interest.
Procedural posture

Chapter 7 debtors contended that the female debtor was entitled to an equitable ownership interest in a vehicle titled solely in the male debtor's name. The trustee objected.

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Consumer opinion summary, case decided on March 10, 2011 , LexisNexis #0411-088

In re Frank

Ruling
IRS entitled to claim payment for erroneous credit pursuant to terms of confirmed plan.
Procedural posture

An examiner sought instructions from the court as to the disbursal of funds to the IRS pursuant to the provisions of a confirmed plan. The debtor claimed the funds, asserting that nothing was owed on the IRS claim.

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Consumer opinion summary, case decided on March 09, 2011 , LexisNexis #0411-100

Campbell v. Hanover Ins. (In re Campbell)

Ruling
Transfer of lender's funds into certificate of deposit was a contemporaneous exchange for new value and not avoidable.
Procedural posture

Chapter 7 trustee filed this adversary proceeding against defendant surety, claiming that it was an indirect beneficiary of the transfer of a lender's funds into a certificate of deposit and the transfer of the funds was avoidable as a preferential transfer under 11 U.S.C.S. § 547. The matter came before the court for hearing on the surety's Fed. R. Civ. P. 56 motion for summary judgment.

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Consumer opinion summary, case decided on November 03, 2010 , LexisNexis #1210-090

In re James

Ruling
Counsel sanctioned for falsifying of credit counseling certificate by paralegal.
Procedural posture

After it was discovered that the credit counseling certificate filed by counsel per 11 U.S.C.S. § 109(h)(1) in connection with a chapter 13 filing made on behalf of debtors had been falsified, a married couple, motions were filed by debtors and by the Bankruptcy Administrator (BA). Issues included whether counsel was properly sanctioned by reason thereof and whether debtors were entitled to voluntarily dismiss the case per 11 U.S.C.S. § 1307.

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Consumer opinion summary, case decided on April 01, 2010 , LexisNexis #0810-107

Andresen & Arronte PLLC v. Hill (In re Hill)

Ruling
Dischargeability proceeding dismissed as to debtor's spouse against whom there was no evidence of fraud.
Procedural posture

Creditor, a law firm which represented defendant debtors in a prepetition state court lawsuit (debtors were also defendants there), brought an adversary proceeding against debtors pursuant to 11 U.S.C.S. § 523(a)(2). At trial, debtors moved for directed verdict after the firm presented its case-in-chief. The court deferred a ruling on that motion until after debtors presented their case.

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Consumer opinion summary, case decided on March 23, 2010 , LexisNexis #0610-087

In re Siler

Ruling
Debtor's retirement plan contributions and loan obligations did not constitute special circumstances that would rebut the presumption of abuse.
Procedural posture

Based on a bankruptcy debtor's projected disposable income, the debtor presumptively abused chapter 7 bankruptcy, but the debtor asserted that disallowed expenditures constituted special circumstances to rebut the presumption based on the debtor's retirement plan contributions, a plan loan obligation, and a student loan obligation. The bankruptcy administrator moved to dismiss the debtor's case.

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Consumer opinion summary, case decided on March 23, 2010 , LexisNexis #0610-100