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§ 1144

In re Wilshire Courtyard

Ruling
Taxing authority that did not timely object to confirmation ordered to cease and desist efforts to collect from debtor.
Procedural posture

A bankruptcy court issued an order requiring the California Franchise Tax Board (FTB) to show cause why it should not be held in contempt for collaterally attacking and refusing to comply with a plan confirmation order. The Chapter 11 debtor moved for summary judgment.

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Commercial opinion summary, case decided on August 31, 2010 , LexisNexis #1010-070

Maxus Capital Group LLC v. Ulrich (In re Level Propane Gases Inc.)

Ruling
Bankruptcy court properly refused to revoke confirmation order where allegations of fraud were insufficient.
Procedural posture

Appellant, a prepetition equipment lessor and creditor of debtors, challenged an order of the U.S. Bankruptcy Court for the Northern District of Ohio granting appellee Plan Administrator's motion to dismiss, Fed. R. Civ. P. 12(b)(6), for failing to state a claim for revocation of confirmation order under 11 U.S.C.S. § 1144. The creditor also appealed the finding its complaint was barred by the doctrines of finality, res judicata, and laches.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on April 02, 2010 , LexisNexis #0610-070

Wilhelm v. Ulrich (In re Level Propane Gases Inc.)

Ruling
Lessor who settled claim did not have standing to appeal confirmation order.
Procedural posture

Appellant, a lessor of the debtors, sought review of an order of the United States Bankruptcy Court for the Northern District of Ohio, which granted appellee plan administrator's motion to dismiss under Fed. R. Civ. P. 12(b)(6) for failing to state a claim the lessor's complaint for revocation of a confirmation order under 11 U.S.C.S. § 1144.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on April 02, 2010 , LexisNexis #0610-069

Nancy Sue Davis Trust v. Davis Petroleum Corp.

Ruling
Appeal of denial of motion to revoke plan confirmation dismissed as moot due to substantial consummation.
Procedural posture

Appellee debtors moved to dismiss the appeal filed by appellant trust on the ground that it was moot. The underlying judgment that was being challenged by appellant was a grant of summary judgment in favor of appellees on appellant's claim that appellee had procured confirmation of a chapter 11 reorganization plan by fraud and that appellant was entitled to an order revoking confirmation per 11 U.S.C.S. § 1144.

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Commercial opinion summary, case decided on March 02, 2009 , LexisNexis #0409-013

Olsen v. 419 Apt. Corp.

Ruling
Bankruptcy court did not err in denying motions to vacate settlement and reconsideration of same.
Procedural posture

Appellant challenged two decisions of the United States Bankruptcy Court for the Southern District of New York. The first decision denied denying appellant's motion to vacate a settlement agreement between appellee apartment corporation, appellant, and appellant's wife (the debtor) on the basis of fraud, and the second decision denied appellant's motion for reconsideration of that decision.

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Consumer opinion summary, case decided on September 19, 2008 , LexisNexis #1008-067

Varde Inv. Partners LP v. Comair Inc. (In re Delta Air Lines Inc.)

Ruling
Belated attempt by five creditors to revoke plan that was nearly unanimously approved dismissed due to lack of standing or factual support.
Procedural posture

Pending was the reorganized defendant debtors' motion under Fed. R. Bankr. P. 7012 and Fed. R. Civ. P. 12(b) to dismiss the Amended Complaint. Plaintiff claimants alleged they held $ 125,000,000 in claims against one or more of the debtors. The Amended Complaint (AC) asserted a single claim under 11 U.S.C.S. § 1144 to revoke debtors' confirmed Plan of Reorganization based upon debtors' alleged fraud in procurement of the confirmation order.

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Commercial opinion summary, case decided on April 30, 2008 , LexisNexis #0608-104

In re Schwartz

Ruling
Creditor's post-confirmation motion for sale of debtor's interest in property denied due to failure to file adversary proceeding.
Procedural posture

Creditor filed a motion for an order requiring the sale of the husband debtor's interest in certain real property. The creditor alleged that this property was not disclosed in the bankruptcy and argued that the proceeds of such sale should be paid to the unsecured creditors.

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opinion summary, case decided on July 31, 2006 , LexisNexis #1006-033

Westchester Surplus Lines Ins. Co. v. Surfside Resort & Suites Inc. (In re Surfside Resort & Suites Inc.)

Ruling
Debtor's failure to notify insurer of bankruptcy was not grounds for revocation where insurer's obligations were not affected by filing.
Procedural posture

Plaintiff, a bankruptcy debtor's property insurer, brought an adversary proceeding against defendants, the debtor and the purchaser of the debtor's hotel under its confirmed plan, seeking to revoke the plan under 11 U.S.C. § 1144 on the ground that defendants conspired to deprive the insurer of notice of the debtor's bankruptcy. Defendants moved to dismiss the complaint and the insurer moved for summary judgment.

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opinion summary, case decided on June 08, 2006 , LexisNexis #0906-067

Salsberg v. Trico Marine Services (In re Trico Marine Servs.)

Ruling
Court dismissed complaint seeking revocation of confirmed plan since a revocation order could not restore the status quo existing before confirmation.
Procedural posture

Plaintiffs brought an adversary proceeding to revoke a confirmation order. The court granted the motion for summary judgment made by defendant reorganized debtors on the ground that the revocation order could not protect innocent third parties, and would cause substantial uncertainty. Plaintiffs supplemented the record, which was treated as a motion for reargument. Plaintiffs also moved to supplement the record a second time.

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opinion summary, case decided on May 05, 2006 , LexisNexis #0606-030

Haskell v. Goldman Sachs & Co. (In re Genesis Health Ventures Inc.)

Ruling
Court affirmed finding that fraud claims against debtor were time barred but remanded the case for determination of whether section 1144 applied to claims against other creditors.
Procedural posture

Plaintiff former debenture holders appealed the decision of the bankruptcy court, which granted a motion to dismiss their complaint alleging that defendants, a debtor and its creditors, committed fraud or made grossly negligent misrepresentations regarding the debtor's value during the period leading up to the confirmation of its bankruptcy reorganization plan.

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opinion summary, case decided on March 29, 2006 , LexisNexis #0506-137