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Paloian v. LaSalle Bank Natl Assn (In re Doctors Hosp. of Hyde Park)

Ruling
Transfers to debtor's creditor by bankruptcy remote special purpose entity while debtor was not insolvent were not avoidable.
Issue(s)
On remand, was a special purpose entity which made transfers to debtor's creditor an alter ego of debtor and was debtor insolvent at the time of the transfers, which would make the transfers avoidable if both conditions were met.

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Commercial opinion summary, case decided on October 04, 2013 , LexisNexis #1113-024

In re Brisco

Ruling
Small Business Administration liens could be avoided where claim was provided for in plan.
Issue(s)
Could second mortgage held by the Small Business Administration, which did not file a proof of claim, be avoided pursuant to the terms of debtors' plan.

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Consumer opinion summary, case decided on August 21, 2013 , LexisNexis #0913-135

In re Ezell

Ruling
Debtor's attorney ordered to disgorge fees due to conflict of interest.

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Consumer opinion summary, case decided on August 07, 2013 , LexisNexis #0813-139

Arenas v. Citibank (In re Arenas)

Ruling
Wholly unsecured second lien could be stripped off.
Issue(s)
Whether chapter 13 debtors were allowed to treat a second mortgage a bank held on their residence as an unsecured claim in their bankruptcy plan.

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Consumer opinion summary, case decided on August 06, 2013 , LexisNexis #0913-040

Hardwick v. Bank of Am. (In re Hardwick)

Ruling
Creditor's second line that was wholly unsecured was void.
Procedural posture

Chapter 13 debtor filed an adversary complaint against defendant creditor to determine the validity of the creditor's lien on the debtor's real property.

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Consumer opinion summary, case decided on June 21, 2013 , LexisNexis #0813-114

Hernandez v. TCF Banking & Sav. (In re Hernandez)

Ruling
Third wholly unsecured mortgage could be stripped off.
Procedural posture

Chapter 13 debtors filed an adversary complaint pursuant to 11 U.S.C.S. § 506(a) and (d) and Fed. R. Bankr. P. 3012 to determine the nature and extent of liens held by defendant bank and secured by the debtors' residence. The bankruptcy court held a trial.

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Consumer opinion summary, case decided on May 10, 2013 , LexisNexis #0613-084

Chicago Patrolmens Fed. Credit Union v. Daymon (In re Daymon)

Ruling
Funds received from employer's tuition assistance program were an educational benefit and nondischargeable.
Procedural posture

Creditor, a credit union that had been defendant debtor's employer, instituted this adversary proceeding seeking determination of nondischargeability of debt against debtor under 11 U.S.C.S. § 523(a)(8). A trial was held.

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Consumer opinion summary, case decided on April 02, 2013 , LexisNexis #0513-051

Chriswell v. Alomari (In re Alomari)

Ruling
Debtor's use of creditor's security deposit resulted in claim that was nondischargeable on grounds of embezzlement.
Procedural posture

Creditor filed a fourth amended complaint against chapter 7 debtors seeking a determination of nondischargeability of debt pursuant to 11 U.S.C.S. § 523(a)(2)(A) and (a)(4).

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Consumer opinion summary, case decided on February 14, 2013 , LexisNexis #0313-087

Harris Trust & Savings Bank v. Gunsteen (In re Gunsteen)

Ruling
Financial statement listing transferred asset did not render debt nondischargeable where creditor did not establish debtor had made the entry.
Procedural posture

Plaintiff bank sued defendant debtor on a claim that her obligation to the bank on a personal guaranty of a loan made to a business that she co-owned was nondischargeable per 11 U.S.C.S. § 523(a)(2)(B) on the ground that the loan had been obtained or renewed by fraud, false representation, false pretenses, and materially false writings including a 2009 financial statement.

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Consumer opinion summary, case decided on February 08, 2013 , LexisNexis #0313-048

FIA Card Servs. v. Galarza (In re Galarza)

Ruling
Debt was nondischargeable due to creditor's prima facie claim to which debtor did not respond.
Procedural posture

Debtor filed a voluntary petition for relief under chapter 7 of the Bankruptcy Code. Creditor timely filed a Complaint to Determine Dischargeability of Debt pursuant to 11 U.S.C.S. § 523(a)(2)(A). The matter was before the court for findings of fact and conclusions of law.

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Consumer opinion summary, case decided on November 30, 2012 , LexisNexis #1212-119