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central district of california

In re Vargas

Ruling
Law firm sanctioned for bringing motion for relief from stay to foreclose without evidentiary support.
Procedural posture

The movant, which was apparently not the mortgagee of record, sought relief from the automatic stay to proceed on the foreclosure of the promissory note and mortgage. The debtor asserted that the promissory note in issue was a forgery and not a valid instrument.

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Consumer opinion summary, case decided on October 22, 2008 , LexisNexis #0209-135

Humphrey-Baker v. United Airlines Inc.

Ruling
Employment discrimination action barred to extent predating debtor employer's plan confirmation.
Procedural posture

Defendant, a former employer of plaintiff employee, filed a motion for summary judgment in the employee's action, which alleged that the employer violated California's Fair Employment and Housing Act (FEHA), Cal. Gov't Code § 12940, by discriminating against her based on her physical disability and by failing to offer reasonable accommodations.

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Commercial opinion summary, case decided on October 21, 2008 , LexisNexis #1108-139

Fearing v. Serror (In re Fearing)

Ruling
Debtor's exempt personal injury settlement proceeds could be distributed to satisfy debt secured by tax lien.
Procedural posture

Appellant debtors challenged an order from a bankruptcy court that granted summary judgment in favor of appellee trustee in the trustee's action for declaratory relief. The trustee sought a determination that the debtors were not entitled to the proceeds from a personal injury settlement. The debtors filed a motion to alter and amend that judgment.

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Consumer opinion summary, case decided on October 21, 2008 , LexisNexis #1108-137

AFI Holding Inc. v. Barclay

Ruling
Bankruptcy court erred in finding that investors in debtor's Ponzi scheme did not exchange reasonably equivalent value up to amount invested.
Procedural posture

Appellants, investors in chapter 7 debtor, challenged a decision of the Bankruptcy Court for the Central District of California, which granted appellee chapter 7 trustee summary judgment in an action to avoid transfers the debtor made to the investors prior to the debtor's bankruptcy pursuant to 11 U.S.C.S. § 544(b). The trustee cross-appealed the bankruptcy courts denial of prejudgment interest.

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Commercial opinion summary, case decided on September 04, 2008 , LexisNexis #1108-029

Hurrell v. Barker (In re Barker)

Ruling
Debtors'alleged nondisclosure of defects in house was not basis for nondischargeable debt where purchaser did not sufficiently investigate.
Procedural posture

Plaintiff purchasers of a house from defendant bankruptcy debtors brought an adversary proceeding against the debtors seeking a determination that the purchasers'claim for the cost of repairs to the house was not dischargeable based on fraud and willful and malicious injury under 11 U.S.C.S. § 523(a)(2)(A), (a)(6). The bankruptcy court conducted a trial.

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Consumer opinion summary, case decided on September 03, 2008 , LexisNexis #1208-095

PM Factors Inc. v. Kriesel (In re Kriesel)

Ruling
Debtor lacked standing to bring breach of contract and fiduciary duty and fraud proceeding where trustee had not abandoned any causes of action.
Procedural posture

Counter-claimant debtor filed counterclaims against counter-defendant creditor and its directors, alleging, inter alia, breach of contract, fraud, breach of fiduciary duty, and interferences with contract and prospective economic advantage. The creditor and directors moved to dismiss the counterclaim.

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Consumer opinion summary, case decided on August 14, 2008 , LexisNexis #0908-052

In re Pro-Fit Holdings Ltd.

Ruling
Application of stay was appropriate provisional relief to bar enforcement of district court order pending recognition of debtors' foreign proceeding.
Procedural posture

Petitioners, the joint administrators of three chapter 15 debtors, sought provisional relief under 11 U.S.C.S. § 1519 to apply 11 U.S.C.S. § 362 to stay the enforcement of a U.S. district court order, following judgment on the merits, attaching the U.S. assets of the debtors. Initially the administrators sought a temporary restraining order, but then modified their request. Two creditors were also before the court.

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Commercial opinion summary, case decided on July 11, 2008 , LexisNexis #1108-130

In re Morales

Ruling
Redemption value of vehicle set at Blue Book value on date of hearing.
Procedural posture

Debtor moved for authority to redeem personal property and approval of associated financing under 11 U.S.C.S. § 722. The matter was before the court to determine the appropriate method for calculating the replacement value of a vehicle under the retail value standard of the second sentence of 11 U.S.C.S. § 506(a)(2).

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Consumer opinion summary, case decided on May 08, 2008 , LexisNexis #0608-087

In re Valley Health Sys.

Ruling
Health care district was eligible under chapter 9 despite failure to negotiate plan of adjustment which would have been impracticable.
Procedural posture

Debtor, a California health care district, filed a petition under chapter 9 of the Bankruptcy Code. A bank that held bonds issued by the district filed an objection to the district's petition, claiming that the district was ineligible for relief under chapter 9, and two unions also filed an objection which asked that the court reject any premise that the bankruptcy resulted from the district's obligations to its employees.

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Commercial opinion summary, case decided on February 20, 2008 , LexisNexis #0508-002

In re Mi La Sul

Ruling
Involuntary petitions filed by unsecured creditor in order to negotiate with foreclosing lender during stay dismissed as filed in bad faith.
Procedural posture

A noticed order to show cause hearing was before the court in six related involuntary bankruptcy cases.

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Court :
Commercial opinion summary, case decided on November 09, 2007 , LexisNexis #1207-071