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western district of washington

In re Primes

Ruling
Relief from stay denied where creditor's attempt to circumvent foreclosure through terms of forbearance agreement was ineffective under state law.
Issue(s)
Did quit claim provided by debtor in connection with a forbearance agreement entitle creditor to relief from stay to take possession of the subject property?

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Consumer opinion summary, case decided on September 26, 2014 , LexisNexis #1014-079

Giebel v. Styron (In re Giebel)

Ruling
Misrepresentation regarding subordination agreement was grounds for nondischargeable debt.
Issue(s)
Was second mortgage debt nondischargeable due to misrepresentations made by debtor to creditor or could the lien be stripped and the claim disallowed?

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Consumer opinion summary, case decided on August 29, 2014 , LexisNexis #0914-114

In re Rental Sys. LLC

Ruling
Debtor's application to employ law firm denied due to failure to comply with disclosure requirements and deadlines.
Issue(s)
Could debtor employ law firm that failed to comply with disclosure requirements and deadlines regarding payment and source of fees and prior representation of affiliates of debtor?

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Commercial opinion summary, case decided on March 17, 2014 , LexisNexis #0414-036

Richer v. Morehead (In re Richer)

Ruling
Portion of claim based on demand note allowed but portion consisting of prepetition interest disallowed.
Issue(s)
Was creditor entitled to unsecured claim based on note, including postpetition interest.

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Consumer opinion summary, case decided on January 09, 2014 , LexisNexis #0214-044

In re Weatherspoon

Ruling
Postpetition funds in trustee's hands revested with debtor after postconfirmation dismissal and could not be paid to debtor's counsel.
Issue(s)
Should postpetition funds in hands of trustee on dismissal of chapter 13 case be paid to debtor or to debtor's counsel.

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Consumer opinion summary, case decided on January 03, 2014 , LexisNexis #0214-003

Donahue v. Smith (In re Pinewood Buffet & Grill Inc.)

Ruling
Bankruptcy court had jurisdiction over creditor lessor's claim for fire insurance proceeds but not over claim against insurers for damages.
Issue(s)
Did bankruptcy court have jurisdiction over creditor's claims for fire insurance proceeds and for damages against the insurer.

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Commercial opinion summary, case decided on December 30, 2013 , LexisNexis #0114-139

Ellis v. IPC (USA), Inc. (In re Pettit Oil Co.)

Ruling
Transfers that did not involve estate property were not avoidable. (Bankr. W.D. Wash.)
Issue(s)
Whether consigned goods delivered to a debtor postpetition become property of the debtor's estate.

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Commercial opinion summary, case decided on December 19, 2013 , LexisNexis #0816-106

Sherron Assocs. Loan Fund XXI (Lacey) LLC v. Thomas (In re Parks)

Ruling
LLC was a "corporation" that could be an "affiliate" or "insider" of debtor.
Issue(s)
Is an LLC a "corporation" under the bankruptcy code definitions of "affiliate" and "insider."

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Consumer opinion summary, case decided on December 18, 2013 , LexisNexis #0114-001

Old Republic Natl Title Ins. Co. v. Levasseur (In re Levasseur)

Ruling
Debt was nondischargeable due to debtor's withdrawal from home equity account she knew was no longer available.
Issue(s)
Was debt nondischargeable for false pretenses and intent to defraud due to debtor's obtaining certified checks from a home equity account that she knew should not have been available.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on December 16, 2013 , LexisNexis #0114-010

Waldron v. Huber (In re Huber)

Ruling
Debtor's ownership interest in entity that was controlling member of LLC was property of the estate.
Issue(s)
Whether a chapter 7 trustee who succeeded to the membership rights of an entity that was owned 100 percent by the debtor, also succeeded to the non-economic membership rights of a subsidiary multi- member L.L.C., when the other L.L.C. member did not consent to the trustee's management interest?

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Consumer opinion summary, case decided on November 25, 2013 , LexisNexis #1213-086