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§ 546

In re Bernard L. Madoff Inv. Sec. LLC

Ruling
Trustee for debtor Ponzi scheme operator was prohibited from recovering payments made to customers who withdrew more than they invested.
Issue(s)
Were payments received by customers of the Madoff Ponzi scheme, who withdrew more from their accounts than they had invested, protected from avoidance as transfers made by a stockbroker "in connection with a securities contract" or "settlement payments?"

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on December 08, 2014 , LexisNexis #0115-019

Chorches v. United States Bank

Ruling
Fraudulent transfer claims dismissed due to expiration of statute of limitations.
Issue(s)
Should fraudulent conveyance proceeding be dismissed for being filed after the expiration of the statute of limitations?

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Consumer opinion summary, case decided on October 15, 2014 , LexisNexis #1114-048

Litzler v. Cooper (In re Margaux Tex. Ventures Inc.)

Ruling
Trustee's untimely fraudulent transfer proceeding dismissed but trustee retained the ability to seek disallowance of the creditor's related claim.
Issue(s)
If a successfully asserted affirmative defense of statute of limitations precludes a trustee from avoiding or recovering a transfer, does this also preclude the transferee's claim from being disallowed under section 502(d)?

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Commercial opinion summary, case decided on May 22, 2014 , LexisNexis #0814-059

Freeland v. CPA Warehouse (In re Livemercial Aviation Holding LLC)

Ruling
Equitable tolling applied due to trustee's inability to obtain information about fraudulent transfer claim.
Issue(s)
Did equitable tolling apply to allow trustee to file an untimely complaint in a fraudulent conveyance proceeding?

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Commercial opinion summary, case decided on March 26, 2014 , LexisNexis #0414-124

Grede v. FCStone LLC

Ruling
Prepetition transfer to investor was made in connection with a securities contract and was protected from avoidance by the safe harbor provision.
Issue(s)
Could debtor investment management firm's prepetition transfer of assets to one customer group at the expense of another be avoided?

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on March 19, 2014 , LexisNexis #0414-023

Woodard v. PSEG Techs. Asset Mgmt. Co. LLC (In re Tougher Indus.)

Ruling
Safe harbor provision applied to payments made by debtor in settlement of leveraged buy out of debtor's predecessor.
Issue(s)
Whether transferees were entitled to summary judgment on complaint emanating from a prepetition leveraged buyout (LBO) of debtor's predecessor in which a chapter 11 trustee sought to avoid and recover, as fraudulent conveyances, the buyout payments made to transferees for debtor's stock.

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Commercial opinion summary, case decided on October 10, 2013 , LexisNexis #1113-055

Burtch v. Opus LLC (In re Opus East LLC)

Ruling
Amendments to complaint in avoidance proceeding allowed due to equitable tolling of statute of limitations.

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Commercial opinion summary, case decided on August 06, 2013 , LexisNexis #0813-125

Bernstein v. Evergreen Line (In re Berkline)

Ruling
Post-statute of limitations amended complaint in avoidance proceeding related back to original filing.
Issue(s)
Whether a putative transferee was entitled to an order dismissing a plan administrator's complaint alleging that he was entitled under 11 U.S.C.S. § 547 to avoid transfers corporate debtors made to the transferee less than ninety days before the debtors declared chapter 11 bankruptcy.

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Consumer opinion summary, case decided on August 06, 2013 , LexisNexis #0813-126

Official Comm. of Unsecured Creditors of Quebecor World (U.S.A) Inc. v. Am. Life Ins. Co. (In re Quebecor World (U.S.A.) Inc.)

Ruling
Payments pursuant to note purchase agreements were within the safe harbor for transfers made in connection with a securities contract
Procedural posture

Appellant committee of unsecured creditors sought to avoid and recover certain payments made by a debtor to appellee noteholders in exchange for private placement notes that had been issued by one of the debtor's affiliates. The bankruptcy court granted the noteholders' motion for summary judgment. The United States District Court for the Southern District of New York affirmed the bankruptcy court's order. The committee appealed.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on June 10, 2013 , LexisNexis #0713-022

Brandt v. PlainsCapital Leasing LLC(In re Equipment Acquisition Res. Inc.)

Ruling
Avoidance proceeding dismissed where evidence of alleged Ponzi scheme was insufficient to establish transfers as presumably fraudulent.
Procedural posture

Bankruptcy plan administrator brought adversary proceedings against transferees of funds from a bankruptcy debtor alleging that the transfers of funds were avoidable as fraudulent. The transferees moved to dismiss the complaints for failures to state claims.

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Commercial opinion summary, case decided on June 06, 2013 , LexisNexis #0713-093