Addressing an issue of first impression, the Second Circuit held recently that bankruptcy courts have inherent authority to impose non-nominal civil contempt sanctions, including per diem sanctions and attorneys’ fees, arising out of an attorney’s failure to comply with the bankruptcy court’s discovery orders.

A Dutch Court of Appeal recently upheld a lower court’s decision that a liquidator has the right to access data concerning the administration of a bankrupt company, the data of which are kept by a third party. It also held that this right, however, does not imply that the third party must provide the data in an orderly manner without being adequately compensated for it.