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southern district of illinois

Buddha Air Ltd. V. Zietlow (In re Zietlow)

Ruling
Debt was dischargeable absent evidence of knowingly false representations intended to deceive creditor.
Procedural posture

Plaintiff creditor brought an adversary proceeding against defendant bankruptcy debtor seeking a determination that a debt to the creditor was nondischargeable under 11 U.S.C.S. § 523(a) based on the debtor's fraud in failing to deliver aircraft starter generators for which the creditor paid the debtor's business.

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Consumer opinion summary, case decided on June 14, 2011 , LexisNexis #0711-117

In re Herrin Clinic Ltd.

Ruling
Debtors' attorneys' interim fees allowed with reduction for unopposed motions, excessive time charges and travel that did not benefit estate.
Procedural posture

Counsel of record for debtors in a bankruptcy case filed an amended application seeking interim attorney fees and reimbursement of expenses for a certain time period.

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Commercial opinion summary, case decided on May 06, 2011 , LexisNexis #0611-073

In re Sykes

Ruling
Untimely proofs of claim disallowed on trustee's objection.
Procedural posture

In separate Chapter 13 cases, bankruptcy debtors failed to list creditors on their schedules, and the creditors filed proofs of claim after the bar date for filing such claims under Fed. R. Bankr. P. 3002. The trustee objected to allowance of the creditors' claims.

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Consumer opinion summary, case decided on April 06, 2011 , LexisNexis #0511-135

Quality Meat Prods. LLC v. PorCo Inc. (In re PorCo Inc.)

Ruling
Alleged fraudulent transfer could not be avoided where state statute of limitations had run.
Procedural posture

Plaintiff creditor brought a two-count adversary complaint against defendants, the debtor corporation and its principal, seeking, in part, to set aside a transfer of real property from 4 and a half years prior, pursuant to 11 U.S.C.S. § 544(b) and 740 ILCS 160/5(a), and under 11 U.S.C.S. § 548(e). Debtor and its principal moved to dismiss the complaint for failure to state a claim for relief.

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Commercial opinion summary, case decided on March 30, 2011 , LexisNexis #0411-123

Great Lakes Pork Inc. v. CIT GroupBus. Credit Inc. (In re Meadowbrook Farms Coop.)

Ruling
Action by vendor against debtor's lender and an officer of the debtor, alleging unjust enrichment, conspiracy and intentional misrepresentation remanded to state court as not arising under or related to debtor's bankruptcy.
Procedural posture

Plaintiff vendors filed a three-count complaint in state court against defendants, a lender of the debtor and an officer of the debtor, alleging unjust enrichment and conspiracy against the lender, and intentional misrepresentation against the officer. The officer removed the action to the court. A conspiracy claim against the officer was added.

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Commercial opinion summary, case decided on January 25, 2011 , LexisNexis #0211-136

In re King

Ruling
Postconfirmation modification of above median debtors' plan was subject to 60-month term requirement.
Procedural posture

Debtors' Second Amended Plan had been confirmed in 2006. Before the court was debtors' Third Amended Plan. The Chapter 13 Trustee objected.

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Consumer opinion summary, case decided on October 20, 2010 , LexisNexis #1110-136

In re Winkles

Ruling
Unemployment compensation funds are not SSA payments and must be included in current monthly income calculation.
Procedural posture

The United States Trustee (UST) filed a motion to dismiss the chapter 7 debtors' case pursuant to 11 U.S.C.S. § 707(b)(1) and (b)(2). The sole issue was whether unemployment compensation benefits received from the State of Illinois prior to filing bankruptcy were benefits received under the Social Security Act (SSA) and therefore excluded from the current monthly income calculation under 11 U.S.C.S. § 101(10A)(B).

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Consumer opinion summary, case decided on July 06, 2010 , LexisNexis #1010-001

In re Walker

Ruling
Debt was dischargeable as tender of dishonored checks by debtors, sole shareholders, officers and directors of a corporation, was not a false representation.
Procedural posture

Plaintiff, a petroleum wholesaler, brought an adversary complaint against defendant debtors, the sole shareholders, officers, and directors of a corporation, seeking to deny the discharge of debts for dishonored corporate checks used to purchase fuel pursuant to 11 U.S.C.S. § 523(a)(2)(A) and (B), and 523(a)(4).

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Consumer opinion summary, case decided on May 24, 2010 , LexisNexis #0810-117

In re Kirkland

Ruling
Objection to amended plan that could have been raised prior to confirmation of original plan overruled as untimely.
Procedural posture

A secured creditor, which was a bank, objected to two debtors' proposed amended plan in their chapter 13 bankruptcy action.

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Consumer opinion summary, case decided on May 20, 2010 , LexisNexis #0810-030

In re Curtis

Ruling
Confirmation necessarily established that plan was filed in good faith.
Procedural posture

A creditor objected to a bankruptcy debtor's chapter 13 plan and moved to dismiss the debtor's case based on lack of good faith. The debtor filed an amended plan which was confirmed without objection.

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Consumer opinion summary, case decided on April 09, 2010 , LexisNexis #0710-063