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western district of new york

In re Flour City Bagels, LLC

Ruling
Sale of assets free and clear could not be approved due to debtor’s failure to exercise soundbusiness judgment in selecting bid. (Bankr. W.D.N.Y.)
Issue(s)
Could debtor bagel franchisee sell substantially all of its assets, free and clear of all liens or interests, to its sole managing member, the prevailing bidder at auction?

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Commercial opinion summary, case decided on September 02, 2016 , LexisNexis #0916-113

In re Palumbo

Ruling
Debtors could not reopen long-closed case for determination on unscheduled debt that wasnow at issue in state court. (Bankr. W.D.N.Y.)
Issue(s)
Could debtors reopen their long-closed chapter 7 bankruptcy cases, to address an unscheduled

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Consumer opinion summary, case decided on September 01, 2016 , LexisNexis #0916-107

In re Schichtel

Ruling
Claim for wrongful death of debtor spouse that arose postpetition but preconversion wasproperty of the estate. (Bankr. W.D.N.Y.)
Issue(s)
Could trustee administer various assets, including debtor spouse’s wrongful death claim, that came into existence after this case was initially filed in chapter 11, but prior to the date of conversion?

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Consumer opinion summary, case decided on August 18, 2016 , LexisNexis #0916-124

Broadway Warehouse Co. v. Schmitt (In re Schmitt)

Ruling
Discharge denied due to debtor’s failure to keep adequate books and records. (Bankr.W.D.N.Y.)
Issue(s)
Should debtor’s discharge be denied for failure to keep adequate records?

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Consumer opinion summary, case decided on August 09, 2016 , LexisNexis #0916-028

In re Denaro

Ruling
Debtors could modify loan that was secured solely by their manufactured home and not theland on which it was placed. (Bankr. W.D.N.Y.)
Issue(s)
Could debtors modify loan secured by their manufactured home?

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Consumer opinion summary, case decided on August 05, 2016 , LexisNexis #0916-064

In re Native Wholesale Supply Co.

Ruling
Allowed claim in favor of state could not be modified postconfirmation.
Issue(s)
Whether the bankruptcy court should reconsider an allowed claim in favor of a state following confirmation of a plan of reorganization?

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Commercial opinion summary, case decided on June 16, 2016 , LexisNexis #0716-066

In re Crowder

Ruling
Sanctions for violation of stay denied absent injury from willful actions.
Issue(s)
Could creditor be sanctioned for violating the automatic stay where debtor suffered no injury or pecuniary loss?

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Consumer opinion summary, case decided on June 16, 2016 , LexisNexis #0716-040

In re Jones

Ruling
Motion for sale of debtor's property free and clear only of the interests of taxing authorities and the first mortgagee granted.
Issue(s)
Should chapter 7 trustee be granted authorization to conduct the auction sale of an over- encumbered parcel of real property?

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Consumer opinion summary, case decided on April 15, 2016 , LexisNexis #0516-111

In re Brooks

Ruling
Debtor could not modify creditor's security interest in debtor's residence in a multi-family property.
Issue(s)
Whether the statutory protection given to secured creditors under 11 U.S.C.S. § 1322(b)(2) applies to a security interest in real property that is a debtor's principal residence, if that residence happens to be a multi-family home with income potential.

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Consumer opinion summary, case decided on April 15, 2016 , LexisNexis #0516-062

In re Birch Grove Landscaping & Nursery Inc.

Ruling
Authority to use cash collateral denied.
Issue(s)
Should debtor in possession be granted authority to use cash collateral for the purpose of making payment on account of the principal owed to the holder of a second lien over objection from the first lienor?

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Commercial opinion summary, case decided on March 28, 2016 , LexisNexis #0516-010