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Rule 3001

In re Calhoun

Ruling
Claim disallowed as lacking evidence of transfer of ownership or servicing agreement and was barred by state statute of limitations.
Procedural posture

Debtors filed an objection to a proof of claim for $800.

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Consumer opinion summary, case decided on May 31, 2013 , LexisNexis #0713-034

In re Carlsen

Ruling
Claim by debtor's former spouse based on amounts owed to third parties and non-existent sale proceeds denied.
Procedural posture

Debtor, the ex-husband of the claimant, objected to a $24,881 claim filed by her, which reflected that $13,798 was a priority claim and that the balance, $11,082, was a general unsecured claim. Issues included whether the claim as filed was properly accorded prima facie validity per Fed. R. Bankr. P. 3001.

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Consumer opinion summary, case decided on March 27, 2013 , LexisNexis #0613-030

In re Jimenez

Ruling
Bank sanctioned for inclusion of unitemized appraisal costs and expenses in proof of claim.
Procedural posture

Debtor filed a petition under chapter 13 of the Bankruptcy Code, and a bank filed a claim against the debtor's bankruptcy estate. The debtor filed an objection to the bank's proof of claim, alleging that the bank failed to properly itemize pre-petition interest, fees, expenses, and other charges included in the amount of its claim, as required under Fed. R. Bankr. P. 3001(c)(2)(A). The court held a hearing on the debtor's objection.

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Consumer opinion summary, case decided on February 01, 2013 , LexisNexis #0213-137

In re Cruse

Ruling
Claim found not to be secured on debtor's objection due to lack of supporting documentation.
Procedural posture

A chapter 13 debtor objected to a creditor's claim, and the creditor objected to the confirmation of the debtor's plan.

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Consumer opinion summary, case decided on January 28, 2013 , LexisNexis #0213-102

In re Tipton

Ruling
Objection to proof of claim for alleged improper documentation overruled.
Procedural posture

A chapter 13 debtor objected to a proof of claim, contending that it did not comply with Fed. R. Bankr. P. 3001 and Bankr. D. Mont. R. 3001(c)(1) and should be disallowed because the creditor did not provide copies of the transfer documents to show chain of title and establish that the rights to said note and deed of trust were transferred to the creditor.

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Consumer opinion summary, case decided on January 11, 2013 , LexisNexis #0213-033

In re QR Props. LLC

Ruling
Claims arising from country club membership subscription agreement between creditors and debtor club owner's predecessor disallowed.
Procedural posture

A chapter 11 debtor filed objections to 32 proofs of claim arising from country club membership subscription agreements between the claimants and the predecessor to the debtor in ownership of the country club.

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Commercial opinion summary, case decided on January 07, 2013 , LexisNexis #0113-133

In re DeBouver

Ruling
Debtor's objection to proof of claim based on contract sustained due to creditor's material breach.
Procedural posture

Chapter 13 debtors objected to a proof of claim filed by a creditor.

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Consumer opinion summary, case decided on December 31, 2012 , LexisNexis #0113-098

Randall v. United States Bank (In re Randall)

Ruling
Bank's properly filed and documented proof of claim was prima facie evidence of the claim's validity.
Procedural posture

In this adversary proceeding plaintiff debtors sought a determination of the validity of defendant bank's secured claim. Debtors and the bank filed competing motions for summary judgment, Fed. R. Civ. P. 56, applicable by virtue of Fed. R. Bank. P. 7056.

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Consumer opinion summary, case decided on December 21, 2012 , LexisNexis #0113-134

In re Evans

Ruling
Claim by estate of debtor's fomer spouse based on domestic relations order that was never entered was unsecured.
Procedural posture

Claimant, the decedent's estate for the former spouse of debtor filed a secured claim against debtor's estate for the funds debtor was obligated to pay the decedent under their separation award. The debtor filed an objection to claim, asserting any such claim was unsecured under the facts of the case.

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Consumer opinion summary, case decided on July 10, 2012 , LexisNexis #0812-035

In re McCormack

Ruling
Failure to provide itemized statement of interest, fees, expenses or charges incurred prepetition was not grounds for disallowance of proof of claim.
Procedural posture

A chapter 13 trustee filed an objection to a proof of claim filed by a creditor on the grounds that the creditor failed to provide an itemized statement of interest, fees, expenses, or charges incurred before the debtors' petition was filed. The trustee sought an order striking the claim to the extent it failed to comply with Fed. R. Bankr. P. 3001(c)(2)(D)(ii).

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Consumer opinion summary, case decided on March 12, 2012 , LexisNexis #0412-035