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Rule 3001

In re Final Analysis Inc.

Ruling
Assignment of claim in involuntary case allowed over creditors' objections.
Procedural posture

Creditors of a corporate debtor filed an involuntary petition against the debtor under chapter 7 of the Bankruptcy Code, and a trustee was appointed to represent the bankruptcy estate. A creditor who was employed by the debtor transferred his claim to an assignee, and other creditors filed an objection to the transfer.

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Commercial opinion summary, case decided on May 16, 2008 , LexisNexis #0708-035

In re Fendall

Ruling
Lis pendens was not evidence of secured claim.
Procedural posture

The debtor filed an objection to creditor's claim asserting that the claim was not in proper form, was not supported by documentation required if the claim was alleged to be secured, and provided insufficient documentation to establish the amount of the claim. Attached to the proof of claim was a lis pendens notice in which the creditor alleged that she advanced a total of at least $ 71,000 to the debtor.

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Consumer opinion summary, case decided on May 08, 2008 , LexisNexis #0808-054

In re Stewart

Ruling
Mortgagee's claims for improper fees disallowed and damages assessed for duplicitous and misleading conduct.
Procedural posture

In connection with an objection filed by a chapter 13 debtor to the second amended claim of a mortgagee, the court ordered the mortgagee to produce documents pertaining to the amounts described therein and considered the proper disposition of the objection under Fed. R. Bankr. P. 3001. At issue, inter alia, was the propriety of charges for inspection fees, appraisal fees, other charges, attorneys fees and costs, and certain "escrow advances."

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Consumer opinion summary, case decided on April 10, 2008 , LexisNexis #0808-128

In re White

Ruling
Proofs of claim disallowed due to assignee creditors' inability to establish validity upon debtors'objection.
Procedural posture

Bankruptcy debtors objected to proofs of claim filed by putative assignees of claims against bankruptcy debtors, on the ground that the proofs of claim failed to include documents evidencing the claims or the assignment of the claims to the assignees as required by Fed. R. Bankr. P. 3001.

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Consumer opinion summary, case decided on January 29, 2008 , LexisNexis #0208-089

In re House of Wines Inc.

Ruling
Claim that did not set forth basis for treatment as prepetition claim was not entitled to presumption of validity.
Procedural posture

Chapter 7 trustee filed an objection to the proof of claim filed by creditor.

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opinion summary, case decided on June 26, 2007 , LexisNexis #0707-120

In re Griffin

Ruling
Failure to provide copy of assignment or transfer of credit card debt was not grounds for disallowance as transfer preceeded filing of proof of claim.
Procedural posture

A creditor filed a proof of claim for an unsecured credit card indebtedness that it had purchased from a bank. The chapter 13 debtors objected to the proof of claim, alleging a lack of documentation and no evidence of the transfer between the bank and the creditor.

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opinion summary, case decided on May 17, 2007 , LexisNexis #0707-070

In re W.R. Grace & Co.

Ruling
71 asbestos-related claims filed by single law firm denied as based on client authorizations that were either undated or dated after bar date.
Procedural posture

Debtors moved for an order disallowing and expunging 71 property damage claims signed by a named law firm on purported behalf of various clients and filed thereafter on the ground that the firm had failed to establish that it had authority, prior to the bar date, to file such claims. At issue was whether the claims were executed by each client's "authorized agent" within the meaning of Fed. R. Bankr. P. 3001(b).

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opinion summary, case decided on April 17, 2007 , LexisNexis #0607-035

Garza v. J.D. Foods Inc. (In re Garza)

Ruling
Court upheld order finding that creditor's pre-bar date motion for relief from bankruptcy stay constituted an informal proof of claim that was timely filed.
Procedural posture

Appellant debtor sought review of an order of the bankruptcy court, which found that appellee creditor's motion for relief from the bankruptcy stay constituted an informal proof of claim that was timely filed.

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opinion summary, case decided on May 15, 2006 , LexisNexis #0606-069

In re Hunt-Shannon

Ruling
Court required debtors to file an affidavit rebutting prima facie validity of creditor's proof of claim and held that debtors had burden of proving payment in full.
Procedural posture

Petitioner debtors filed an objection to respondent creditor's proof of claim on a loan made to a debtor.

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opinion summary, case decided on May 04, 2006 , LexisNexis #0606-032

In re Schrandt

Ruling
Debtors failed to overcome the prima facie evidence of the validity of the creditor's claim.
Procedural posture

Bankruptcy debtors'plan was confirmed and the trustee's claims report allowed a creditor's claim secured by the debtors'automobile and the creditor's unsecured claim for the balance of the amount owed which was greater than the value of the vehicle. The debtors objected to allowance of the unsecured portion of the claim, asserting that the creditor agreed to waive the unsecured claim.

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opinion summary, case decided on March 20, 2006 , LexisNexis #0406-032