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§ 1127(b)

Rental Car Intermediate Holdings LLC, In re--Wells Fargo Bank, N.A. v. U.S. Bank N.A.

Ruling
Indenture trustees’ request for bond to cover noteholders' disputed claims denied as it would improperly modify confirmed plan post-substantial consummation and result in preferential treatment. (Bankr. D. Del.)
Issue(s)
Modification of Plan; After Confirmation and Before Substantial Consummation.

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Commercial opinion summary, case decided on January 02, 2025 , LexisNexis #0325-015

Heritage Collegiate Apparel, In re

Ruling
Debtor ordered to amend plan and disclosures to ensure clarity, transparency and compliance with the Bankruptcy Code. (Bankr. E.D. Mich.)
Issue(s)
Modification of Plan; After Confirmation and Before Substantial Consummation.

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Consumer opinion summary, case decided on December 20, 2024 , LexisNexis #0325-014

Northeast Gas Generation, LLC

Ruling
Court denied motion to reopen debtor’s Chapter 11 case to make even a small modificationdenied as the plan had been substantially consumated. (Bankr. D. Del.)
Issue(s)
Modification of Plan; After Confirmation and Before Substantial Consummation.

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Commercial opinion summary, case decided on March 18, 2022 , LexisNexis #0522-045

SS Body Armor I, Inc., In re

Ruling
Trustee's requested extension of term of recovery trust was not a modification of the plan andcould be allowed. (Bankr. D. Del.)
Issue(s)
Modification of Plan; After Confirmation and Before Substantial Consummation.

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Commercial opinion summary, case decided on June 07, 2021 , LexisNexis #0721-094

Boise Gun Co., In re

Ruling
Debtor's motion to modify its chapter 11 plan was denied where the plan was substantiallyconsummated at the time it filed its motion. (Bankr. D. Idaho)
Issue(s)
Modification of Plan; After Confirmation and Before Substantial Consummation.

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Commercial opinion summary, case decided on January 12, 2018 , LexisNexis #0218-086

Shefa, LLC, In re

Ruling
Court denied City's motion seeking an order to compel the debtor to deed a property to the City as there was no "Event of Default" by the debtor under the terms of the confirmation order. (Bankr. E.D. Mich.)
Issue(s)
Modification of Plan; After Confirmation and Before Substantial Consummation.

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Commercial opinion summary, case decided on December 22, 2017 , LexisNexis #0118-113

In re Electric Maint. & Constr. Inc.

Ruling
Unsecured creditors lacked standing to compel modification of plan.
Issue(s)
Whether a reorganized debtor under a confirmed Chapter 11 plan can be compelled by an unsecured creditor to modify its plan to account for the resolution of a secured creditor's claim that, in theory, frees up cash for distribution to unsecured creditors?

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Commercial opinion summary, case decided on May 19, 2016 , LexisNexis #0616-063

In re Lemus

Ruling
Debtor not prohibited from filing chapter 13 case less than six months after prior chapter 11 case was closed.
Issue(s)
Could debtor file a chapter 13 case six months after substantial consummation and closing of prior chapter 11 case?

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Consumer opinion summary, case decided on September 17, 2014 , LexisNexis #1014-060

In re Archway Homes Inc.

Ruling
Debtor could not modify substantially consummated plan.
Issue(s)
Could debtor modify plan where it had made substantially all required transfers of real property and paid or dealt with all classes of claims included in the plan .

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Commercial opinion summary, case decided on October 30, 2013 , LexisNexis #1113-096

In re Triumph Christian Ctr. Inc.

Ruling
Debtor's second chapter 11 case filed after substantial consummation of first case and on eve of foreclosure dismissed for bad faith.
Procedural posture

After a bankruptcy debtor's plan of reorganization was substantially consummated, and shortly before a creditor's foreclosure sale of the debtor's property, the debtor filed a successive chapter 11 bankruptcy petition. The creditor moved to dismiss the second petition as an impermissible attempt in bad faith to modify the prior plan in violation of 11 U.S.C.S. § 1127(b).

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Commercial opinion summary, case decided on May 24, 2013 , LexisNexis #0613-135