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western district of arkansas

In re Patel

Ruling
Case converted to chapter 7 due to diminution of estate, gross mismanagement and lack of rehabilitation potential.
Procedural posture

A corporation wholly owned by bankruptcy debtors owned and operated a convenience store which suffered declining revenues due to increased competition, and the debtors' expenses exceeded their income. A creditor moved pursuant to 11 U.S.C.S. § 1112(b) to convert the debtor's chapter 11 case to chapter 7 or to dismiss the case.

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Consumer opinion summary, case decided on August 23, 2012 , LexisNexis #1012-094

In re Covel

Ruling
Debtor could not be required to reaffirm secured debt despite statement of intent to do so.
Procedural posture

Debtor filed a petition under chapter 7, and a bank that held a secured interest in the debtor's home filed a motion for an order requiring the debtor to reaffirm a debt she owed on her home, redeem the property, or surrender the property. The court held a hearing on the bank's motion.

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Consumer opinion summary, case decided on July 03, 2012 , LexisNexis #0712-117

Gomez v. Wells Fargo Bank (In re Gomez)

Ruling
Reaffirmation agreement was valid despite failure to separate fees and costs or provide repayment schedule.
Procedural posture

Plaintiff bankruptcy debtors brought an adversary proceeding against creditor seeking a declaration that an agreement whereby the debtors reaffirmed their debt to the creditor secured by the debtors' home was null and void based on lack of compliance with the statutory requirements of 11 U.S.C.S. § 524.

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Consumer opinion summary, case decided on May 24, 2012 , LexisNexis #0712-023

Conine v. Foster (In re Foster)

Ruling
Discharge denied due to debtor's failure to omissions from schedules.
Procedural posture

Judgment creditor filed an adversary proceeding against chapter 7 debtor, seeking a determination that a judgment she obtained in state court was nondischargeable under 11 U.S.C.S. § 523, a determination that the debtor was not eligible under 11 U.S.C.S. § 727(a)(2)(B), (a)(3), and (a)(4)(A) to have his debts discharged. The creditor withdrew her claim under § 523, and her claims under § 727 were tried to the court.

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Consumer opinion summary, case decided on April 20, 2012 , LexisNexis #0512-135

Caine v. First State Bank (In re Caine)

Ruling
Debtors in possession could avoid defective lien as bona fide purchasers.
Procedural posture

Chapter 12 debtors in possession filed an adversary proceeding to set aside creditor bank's mortgage lien on real property pursuant to 11 U.S.C.S. § 544(a)(1), (3), because the legal description in the recorded mortgage was defective. The bank counterclaimed for reformation of the mortgage granted.

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Consumer opinion summary, case decided on December 08, 2011 , LexisNexis #0212-089

In re Cameron

Ruling
Claim under oral agreement disallowed as paid in full.
Procedural posture

The Chapter 13 debtors objected to a creditor's claim pursuant to 11 U.S.C.S. § 502(b)(1) on the grounds that it was based on an unenforceable agreement. The court examined Arkansas law to determine if there was an enforceable contract between the debtors and the creditor. Both parties sought attorneys' fees.

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Consumer opinion summary, case decided on May 17, 2011 , LexisNexis #0611-047

In re Caterbone

Ruling
Circuit court lacked jurisdiction to hear appeal of district court dismissal of untimely appeal.
Procedural posture

Appellant debtor's Chapter 11 bankruptcy petition was dismissed. The debtor filed an untimely appeal. The appeal was docketed, and the U.S. District Court for the Eastern District of Pennsylvania dismissed the appeal for failing to comply with Fed. R. Bankr. P. 8002(a). The debtor appealed. The trustee moved to dismiss the appeal because the appeal from the bankruptcy court's order was untimely.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on April 04, 2011 , LexisNexis #0411-140

Williams v. Pillar Capitol Holdings LLC (In re Living Hope Southwest Med. Servs. LLC)

Ruling
Transfers from debtor medical center to creditor LLC were avoidable as not made in the ordinary course of business.
Procedural posture

Citing 11 U.S.C.S. § 549, plaintiff trustee sought to avoid allegedly unauthorized post-petition transfers from debtor medical center to defendant LLC, a creditor of debtor, and to LLC's sole member. Issues included whether the transfers were extensions of credit in the ordinary course per 11 U.S.C.S. § 364 that were properly approved nunc pro tunc and whether, if the LLC was found to be liable, the sole member was had personal liability.

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Commercial opinion summary, case decided on March 14, 2011 , LexisNexis #0411-043

In re Miller

Ruling
Enforcement limitations period of health care creditor's lien, which was perfected prior to petition date, was tolled while debtor's case was pending.
Procedural posture

Debtor filed a petition under chapter 13, and a health center filed a claim in the amount of $610 against the debtor's bankruptcy estate. The debtor filed an objection to the claim, alleging that it was void because it was perfected in violation of the automatic stay.

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Consumer opinion summary, case decided on February 14, 2011 , LexisNexis #0311-004

In re Giles

Ruling
Use of portion of real property for family operated business did not invalidate debtors' homestead exemption.
Procedural posture

Bankruptcy debtors claimed a homestead exemption in real property upon which was located the debtors' residence and four rental storage units, and a creditor asserted that the portion of the property containing the storage units was used for business and thus abandoned as part of the homestead. The creditor objected to the debtor's claimed exemption in the entire property.

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Consumer opinion summary, case decided on January 06, 2011 , LexisNexis #0211-080