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§ 503(b)(1)(A)

In re Center Field Props. LLC

Ruling
Creditor entitled to administrative expense claim for portion of fee earned between petition date and rejection of licensing agreement.
Procedural posture

Creditor of chapter 11 debtor filed a motion for payment of a sum as a post- petition administrative claim under 11 U.S.C.S. § 503(b)(1)(A) based on a license agreement with the debtor. The debtor filed an objection to the amount requested.

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Commercial opinion summary, case decided on July 03, 2013 , LexisNexis #0713-114

Teta v. Chow (In re TWL Corp.)

Ruling
Denial of class certification of WARN Act administrative expense claim reversed.
Procedural posture

In an adversary proceeding to enforce the Worker Adjustment and Retraining Notification Act (WARN Act), 29 U.S.C.S. §§ 2101-2109, against debtor employer, the bankruptcy court denied appellant employee's motion for class certification and granted the Trustee's motion to dismiss. The United States District Court for the Eastern District of Texas affirmed the bankruptcy court's order. The employee appealed.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on March 29, 2013 , LexisNexis #0413-118

In re Rattler

Ruling
Administrative expense claim allowed for debtor's postpetition rental arrearage.
Procedural posture

Debtor's chapter 13 matter was before the court pursuant to a creditor's Motion to Allow Administrative Claim related to debtor's failure to meet her obligations to pay rent under a post-petition residential lease.

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Consumer opinion summary, case decided on March 06, 2013 , LexisNexis #0313-112

Conn v. Dewey & Leboeuf LLP (In re Dewey & Leboeuf LLP)

Ruling
Administrative priority status of WARN Act claims not asserted in adversary proceeding had to be determined in debtor's main case.
Procedural posture

In a putative class action adversary proceeding, plaintiff employee sought relief for alleged violations of the Federal Worker Adjustment and Retraining Notification (WARN) Act and a determination that the alleged class claims are entitled to administrative expense or wage priority status. Defendant, a chapter 11 debtor, filed a motion to dismiss under Fed. R. Civ. P. 12(b)(6).

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Commercial opinion summary, case decided on February 11, 2013 , LexisNexis #0313-008

In re Azevedo

Ruling
Administrative expense claim by creditor who sold feed to debtor during pendency of chapter 13 case allowed.
Procedural posture

A chapter 7 trustee objected to a creditor's application for an administrative expense claim under 11 U.S.C.S. § 503(b)(1)(A) with respect to purchases by the debtor from the creditor during the pendency of the debtor's chapter 12 case. The trustee alleged that the transactions did not occur in the ordinary course of business for purposes of 11 U.S.C.S. § 364(a).

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Consumer opinion summary, case decided on January 22, 2013 , LexisNexis #0213-047

In re Grubb & Ellis Co.

Ruling
Real estate brokers not entitled to administrative expense claim for commission where right to payment arose postpetition.
Procedural posture

Movants, real estate brokers formerly associated with debtor brokerages, asked the court to allow their claim for administrative expenses per 11 U.S.C.S. § 503(b)(1)(A). Both debtors and the unsecured creditors' committee objected to the underlying motion and to the claim on the ground that it was not properly classified as an "administrative expense" thereunder.

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Commercial opinion summary, case decided on October 02, 2012 , LexisNexis #1012-119

In re Pulliam

Ruling
Pro se debtor's application for compensation denied except for utility and storage costs.
Procedural posture

Chapter 7 debtor filed a notice of application for payment of professional fees and costs in the total amount of $368,582, including $312,000 for her own labor billed at $300 per hour, and $27,000 for her co-debtor's labor billed at $60 per day. The Trustee filed an objection.

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Consumer opinion summary, case decided on September 26, 2012 , LexisNexis #1012-077

Executive Sounding Bd. Assocs. V. Moshannon Valley Citizens Inc. (In re Moshannon Valley Citizens Inc.)

Ruling
Financial advisor not entitled to fees and expenses not necessary to preserve value of estate and not included in approved retainer agreement.
Procedural posture

Chapter 11 debtor's financial advisor, filed a motion to enforce a compensation order previously entered in the debtor's bankruptcy case and to obtain reimbursement of the fees and expenses that it incurred in filing the motion.

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Commercial opinion summary, case decided on April 24, 2012 , LexisNexis #0512-050

LAX Enter. L.P. v. RadLAX Gateway Hotel LLC (In re RadLAX Gateway Hotel LLC)

Ruling
Administrative expense claim for debtor's occupation of property over creditor's non-exclusive easement properly disallowed.
Procedural posture

Appellant property owner challenged a decision of the U.S. Bankruptcy Court for the Northern District of Illinois, which denied the owner's administrative claim under 11 U.S.C.S. § 503(b) against appellee debtors.

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Commercial opinion summary, case decided on January 26, 2012 , LexisNexis #0212-080

In re Resource Tech. Corp.

Ruling
Denial of administrative expense claim for hotel allegedly devalued by debtor's adjacent failed landfill affirmed.
Procedural posture

After conversion from Chapter 11 to 7, and four days after a trustee was appointed, the debtor's gas collection system at a landfill failed, creating a nuisance to a neighboring hotel, whose owner, as a creditor, filed an 11 U.S.C.S. §§ 503(b)(1)(A), 507(a)(2), administrative claim. The U.S. District Court for the Northern District of Illinois, Eastern Division, affirmed the rejection of the administrative claim. The owner appealed.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on October 31, 2011 , LexisNexis #1111-105