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In re Holt

Ruling
Debtor could not claim state exemptions in note payable to LLC rather than in distributional interests in LLC.
Issue(s)
Could debtors claim state exemptions in note payable to LLC of which each had held a 50 percent interest and still had distributional interests.

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Consumer opinion summary, case decided on September 12, 2013 , LexisNexis #1013-010

In re Oncale

Ruling
Retroactive relief from stay to validate postpetition foreclosure denied.
Issue(s)
Whether there were grounds for granting a creditor's motion seeking retroactive relief from the stay that was imposed when a debtor declared chapter 13 bankruptcy, in order to validate a foreclosure sale that occurred after the debtor declared bankruptcy and an action evicting the debtor from his residence.

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Consumer opinion summary, case decided on August 28, 2013 , LexisNexis #1013-038

Taylor v. Davis (In re Davis)

Ruling
Debt was nondischargeable based on debtor's false statements regarding use of funds and embezzlement.

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Consumer opinion summary, case decided on July 26, 2013 , LexisNexis #0813-082

In re Colonial Warehouse LLC

Ruling
Case filed on eve of foreclosure with little potential for rehabilitation dismissed for lack of good faith.
Procedural posture

A creditor filed a motion to dismiss or, in the alternative, to convert a case under chapter 11 to a case under chapter 7 pursuant to 11 U.S.C.S. § 1112(b)(1). The chapter 11 debtor opposed the motion.

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Commercial opinion summary, case decided on May 20, 2013 , LexisNexis #0613-133

Rockstone Capital LLC v. Caimano (In re Caimano)

Ruling
Discharge denied due to debtor's disposal of property in violation of post-judgment state court order.
Procedural posture

In an adversary proceeding, plaintiff creditor, who had obtained a state court judgment against defendant debtor prior to the debtor's bankruptcy filing, and who had engaged in state court proceedings to collect on this judgment, sought a denial of discharge under 11 U.S.C.S. § 727(a)(2). The court issued its findings of fact and conclusions of law.

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Consumer opinion summary, case decided on May 13, 2013 , LexisNexis #0613-096

In re Ervin

Ruling
Debtor's failure to file statement of intention with regard to judicial lien impairing exemption did not preclude avoidance.
Procedural posture

This matter was before the court on debtor's motion to avoid the judicial lien of a lienholder.

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Consumer opinion summary, case decided on May 02, 2013 , LexisNexis #0613-048

In re Bamberg County Mem. Hosp.

Ruling
Settlement of claim after LLC's purchase of debtor's assets failed to close approved.
Procedural posture

Debtor hospital filed a petition under chapter 9 of the Bankruptcy Code, and an LLC that agreed to purchase the debtor's assets filed a claim in the amount of $1,054,173 against the debtor's bankruptcy estate after the sale did not close. The debtor and the LLC settled the LLC's claim, and the debtor asked the court to approve the settlement pursuant to Fed. R. Bankr. P. 9019. A company that sold health care equipment filed an objection.

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Commercial opinion summary, case decided on April 18, 2013 , LexisNexis #0513-103

In re Barnwell County Hosp.

Ruling
Chapter 9 debtor's motion for authorization of substitute asset purchase agreement granted.
Procedural posture

Chapter 9 debtor, a rural hospital, filed a motion for authorization of a substitute asset purchase agreement (APA). Several parties objected to the motion. The debtor also filed a notice and application for settlement and compromise between the debtor and the original buyer under an earlier APA.

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Commercial opinion summary, case decided on April 18, 2013 , LexisNexis #0513-094

In re Johnson

Ruling
Debtor's fifth case in five years dismissed with prejudice on grounds of bad faith.
Procedural posture

Debtor filed a petition under chapter 11 of the Bankruptcy Code, and the United States Trustee ("UST") filed a motion for an order dismissing the debtor's case with prejudice for bad faith filing and seeking in rem relief against real property the debtor owned in Columbia, South Carolina. The debtor filed an objection to the UST's motion, and the court held a hearing on the motion and the debtor's objection.

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Consumer opinion summary, case decided on April 18, 2013 , LexisNexis #0513-092

In re Strickland

Ruling
Case dismissed for unreasonable delay and bad faith.
Procedural posture

Debtor filed a petition under chapter 12 of the Bankruptcy Code, and a bank that held secured claims against property the debtor owned filed a motion to dismiss the debtor's case. Another bank joined the motion, as did the chapter 12 trustee.

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Consumer opinion summary, case decided on March 07, 2013 , LexisNexis #0413-063