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    Subjective Intent to Assume Unexpired Lease of Nonresidential Real Property Deemed Insufficient
    2016-07-20

    Pursuant to a provision of the Bankruptcy Code familiar to readers of Weil’s Bankruptcy Blog (see our prior post, To Assume or Not to Assume, that Is the Question: What Act Constitutes “Assumption” Under Section 365(d)(4) of the Bankruptcy Code?), the United States District Court for the District of Delaware recently affirmed a bankruptcy c

    Filed under:
    USA, Delaware, Insolvency & Restructuring, Litigation, Real Estate, Weil Gotshal & Manges LLP, Bankruptcy, Debtor, Landlord, Debtor in possession, US Code, Title 11 of the US Code, United States bankruptcy court, US District Court for District of Delaware
    Authors:
    Lauren Tauro
    Location:
    USA
    Firm:
    Weil Gotshal & Manges LLP
    Second Circuit: “Free and Clear” Asset Sale in GM Bankruptcy Does Not Shield GM from Liability for Pre-Sale Ignition Switch Defects
    2016-07-21

    In 2009, General Motors (“Old GM”) commenced a chapter 11 case and sold the bulk of its business and assets to a new entity (“New GM”) “free and clear” of liabilities against New GM. Notwithstanding the “free and clear” language of the 2009 sale order (the “Sale Order”), a Second Circuit panel recently held that plaintiffs could assert claims against New GM over faulty ignition switches in cars manufactured by Old GM and recalled in early 2014.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, ArentFox Schiff, Bankruptcy, Debtor, General Motors, Title 11 of the US Code, Second Circuit
    Authors:
    George P. Angelich , Manuel G. Arreaza
    Location:
    USA
    Firm:
    ArentFox Schiff
    Freedom of Contract in LLC Structure Is Not Absolute Where Parties Seek Bankruptcy Relief
    2016-07-21

    In re Intervention Energy Holdings, LLC, Case No. 16-11247 (D. Del. June 3, 2016), the Bankruptcy Court for the District of Delaware dealt with the issue of whether a Delaware LLC lacked authority to file a Chapter 11 petition under the Bankruptcy Code because the limited liability company agreement of the LLC in question required the consent of all members and one member did not consent to the filing.

    Filed under:
    USA, Delaware, Company & Commercial, Insolvency & Restructuring, Litigation, McCarter & English LLP, Bankruptcy, Debtor, Limited liability company, Delaware Supreme Court, United States bankruptcy court
    Authors:
    Philip D. Amoa , Benjamin A. Smyth , Daniel M. Silver , Jameson A.L. Tweedie , Daniel J. Brown
    Location:
    USA
    Firm:
    McCarter & English LLP
    Assignment for the Benefit of Creditors: Stay of Litigation
    2016-07-22

    This is the first of three follow-up blogs to our earlier publication Assignment for the Benefit of Creditors: General Overview. This blog explores ABC’s lack of statutory automatic stay and whether there is a functional and practical equivalent. The next blog will discuss whether a creditor may file a claim after the statutory 120-day deadline.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Jimerson & Cobb P.A., Bankruptcy, Costs in English law, Debtor, Collateral (finance), Personal property, Bad faith, Seventh Circuit
    Authors:
    Austin B. Calhoun, Esq. , Kayla Haines
    Location:
    USA
    Firm:
    Jimerson & Cobb P.A.
    Back to Square One … Eighth Circuit Bankruptcy Appellate Panel Reverses Motion to Dismiss Bankruptcy Case Based on Reversal of Three Year Old Ruling
    2016-07-25

    We have written on other occasions on Civic Partners Sioux City, LLC.

    Filed under:
    USA, Iowa, Insolvency & Restructuring, Litigation, Weil Gotshal & Manges LLP, Bankruptcy, Debtor, Limited liability company, Debt, Consent, Mortgage loan, Eighth Circuit, United States bankruptcy court, Bankruptcy Appellate Panel
    Authors:
    Brenda L. Funk
    Location:
    USA
    Firm:
    Weil Gotshal & Manges LLP
    “You Can’t Always Get What You Want” - - Denial of Claimed Exemptions for Offshore Annuities
    2016-07-25

    The bankruptcy courts have a long history of being willing to use their judicial power under the Bankruptcy Code to prevent perceived efforts by debtors to inappropriately shield their assets from creditors. This is true even when the debtors employ structures and devices that are complex and crafted in seeming compliance with applicable law.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Squire Patton Boggs, Tax exemption, Bankruptcy, Conflict of laws, Debtor, Annuity, Life annuity, Tax haven, Securities fraud, Internal Revenue Service (USA), US Securities and Exchange Commission, United States bankruptcy court
    Authors:
    G. Christopher Meyer
    Location:
    USA
    Firm:
    Squire Patton Boggs
    Are Those Taxes Owing On Your Late-Filed Tax Return Dischargeable? Maybe, But You Better Be In The Right Circuit
    2016-07-25

    Individual debtors with old tax debts relating to late-filed tax returns may be surprised to find that those tax debts may not be dischargeable under section 523(a) of the Bankruptcy Code due to the lateness of the tax filing. There is a current Circuit split regarding whether a late tax filing constitutes a “return” at all, which is critical to the dischargeability inquiry. The Ninth Circuit weighed in last week in In re Smith, 2016 WL 3749156 (9th Cir. July 13, 2016), further cementing the split.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Tax, Bryan Cave Leighton Paisner (Bryan Cave), Debtor, Debt, Tax return (USA), Perjury, Internal Revenue Service (USA), Title 11 of the US Code, Ninth Circuit
    Authors:
    Justin A. Sabin , Bryce A. Suzuki
    Location:
    USA
    Firm:
    Bryan Cave Leighton Paisner (Bryan Cave)
    Improper Use of Contract Attorneys, Failure to Disclose Terms - This Case Has It All
    2016-07-18

    Estate professionals are under continued scrutiny. Unlike other professionals, getting paid is not simply a matter of sending a bill. The bankruptcy court, appropriately so, closely oversees the amount and timing of payment of estate professional fees. And proper disclosure under the Bankruptcy Code and the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”) is critical for all estate professionals.

    Filed under:
    USA, Insolvency & Restructuring, Legal Practice, Litigation, Bryan Cave Leighton Paisner (Bryan Cave), Regulatory compliance, Bankruptcy, Debtor, Independent contractor, Discovery, Legal burden of proof, Constitutional amendment, US Code, United States bankruptcy court, US District Court for District of Columbia
    Location:
    USA
    Firm:
    Bryan Cave Leighton Paisner (Bryan Cave)
    First Circuit Affirms Sanctions Order From Massachusetts Bankruptcy Court Requiring Bankruptcy Attorney to Return to Law School For Ethics Class
    2016-07-18

    “Whoever is careless with the truth in small matters cannot be trusted with important matters.”

    – Albert Einstein

    Filed under:
    USA, Massachusetts, Insolvency & Restructuring, Litigation, Weil Gotshal & Manges LLP, Bankruptcy, Debtor, Collateral (finance), Foreclosure, Misrepresentation, Frivolous litigation, United States bankruptcy court, First Circuit, US District Court for District of Massachusetts
    Location:
    USA
    Firm:
    Weil Gotshal & Manges LLP
    Expanding the Defense of Ordinary Course and Widening the Range of Acceptable Payments During the Historical Period
    2016-07-18

    The Seventh Circuit Court of Appeals in Unsecured Creditors Committee of Sparrer Sausage Co., Inc. v. Jason’s Foods, Inc., 2016 WL 3213090 (7th Cir. June 10, 2016) expanded the scope of the ordinary course defense in a bankruptcy preference action.  This case provides an excellent road map for a creditors’ rights attorney defending a preference suit and suggests arguments for increasing the payments a creditor can retain even if those payments were made during the 90-day preference period.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Porter Wright Morris & Arthur LLP, Credit history, Bankruptcy, Debtor, United States bankruptcy court, Seventh Circuit
    Authors:
    Walter Reynolds
    Location:
    USA
    Firm:
    Porter Wright Morris & Arthur LLP

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