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    Second Circuit affirms dismissal of employees' lender liability WARN Act suit
    2007-09-28

    The United States Court of Appeals for the Second Circuit on Aug. 30, 2007, affirmed the dismissal of a lender liability class action brought by employees of a defunct originator and seller of mortgages and home equity loans. 2007 U.S. App. LEXIS 20791 (2d Cir. August 30, 2007). Agreeing with the district court, the Second Circuit held that the lender was not an "employer" within the meaning of the Worker Adjustment & Retraining Notification Act ("WARN Act"), and thus was not liable to the employees for the sudden loss of their jobs. Id., at *2.

    Filed under:
    USA, Banking, Employment & Labor, Insolvency & Restructuring, Litigation, Schulte Roth & Zabel LLP, Debtor, Fraud, Class action, Interest, Default (finance), Line of credit, US Code, Worker Adjustment and Retraining Notification Act 1988 (USA), Second Circuit, Ninth Circuit
    Location:
    USA
    Firm:
    Schulte Roth & Zabel LLP
    Third Circuit Rejects Side-Switching Disqualification Claim
    2022-07-25

    The Third Circuit recently affirmed the bankruptcy court's approved retention of the debtor's counsel ("S") when that "law firm dropped an existing client to avoid conflicts that would prevent it from taking on a more lucrative client [i.e., the debtor]." In re Boy Scouts of America, 2022 WL 1634643, *7 (3d Cir. May 24, 2022) (BSA). According to the court, there were "not enough facts to put [the so-called "hot potato" doctrine] into play" and disqualify S under the Rules of Professional Conduct. Id.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Schulte Roth & Zabel LLP, United States bankruptcy court, Third Circuit
    Authors:
    Michael L. Cook
    Location:
    USA
    Firm:
    Schulte Roth & Zabel LLP
    Update on Business Bankruptcy Legal Fees and Professionalism
    2021-06-11

    "`Staggering' legal fees in Boy Scouts Bankruptcy Case." So read the title of an article in The New York Times on May 11, 2021. According to the reporter, a "lawyer negotiating a resolution to the multi-billion dollar bankruptcy filed by the Boy Scouts of America billed $267,435 in a single month. Another charged $1,725 for each hour of work. New lawyers fresh out of law school have been billing at an hourly rate of more than $600." The bankruptcy judge presiding over the case has called the fee totals "staggering," said the reporter.

    Filed under:
    USA, Insolvency & Restructuring, Legal Practice, Litigation, Schulte Roth & Zabel LLP
    Authors:
    Michael L. Cook
    Location:
    USA
    Firm:
    Schulte Roth & Zabel LLP
    Third Circuit Allows Repossessing Secured Lender to Hold Collateral Pending Bankruptcy Stay
    2019-12-18

    “[A] secured creditor [has no] affirmative obligation under the automatic stay to return a debtor’s [repossessed] collateral to the bankruptcy estate immediately upon notice of the debtor’s bankruptcy,” the U.S. Court of Appeals for the Third Circuit held on Oct. 28, 2019. In re Denby-Peterson, 2019 WL 5538570, 1 (3d Cir. Oct. 28, 2019). Affirming the lower courts, the Third Circuit joined “the minority of our sister courts — the Tenth and D.C. Circuits” with its holding.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Schulte Roth & Zabel LLP, Title 11 of the US Code, Third Circuit
    Authors:
    Michael L. Cook
    Location:
    USA
    Firm:
    Schulte Roth & Zabel LLP
    Fifth Circuit Blocks Fraudulent Transferee’s Good Faith Defense
    2019-01-16

    “A … transferee [who] received fraudulent transfers with actual knowledge or inquiry notice of fraud or insolvency” loses any “good faith” defense available under the Texas version of the Uniform Fraudulent Transfer Act (“TUFTA”), held the U.S. Court of Appeals for the Fifth Circuit on Jan. 9, 2019. Janvey v. GMAG LLC, 2019 WL 141107, *3 (5th Cir. Jan. 9, 2019) (emphasis added).

    Filed under:
    USA, Texas, Insolvency & Restructuring, Litigation, White Collar Crime, Schulte Roth & Zabel LLP, Due diligence, US Securities and Exchange Commission, European Securities and Markets Authority, Fifth Circuit, Texas Supreme Court, U.S. Court of Appeals
    Authors:
    Michael L. Cook
    Location:
    USA
    Firm:
    Schulte Roth & Zabel LLP
    Second Circuit Rejects Arbitration of Debtor’s Asserted Discharge Violation
    2018-04-03

    A bankruptcy court properly denied a bank’s motion to compel arbitration of a debtor’s asserted violation of the court’s discharge injunction, held the U.S. Court of Appeals for the Second Circuit on March 7, 2018. In re Anderson, 2018 U.S. App. LEXIS 5703, *20 (2d Cir. March 7, 2018).

    Filed under:
    USA, Arbitration & ADR, Insolvency & Restructuring, Litigation, Schulte Roth & Zabel LLP, Second Circuit
    Authors:
    Michael L. Cook
    Location:
    USA
    Firm:
    Schulte Roth & Zabel LLP
    Sixth Circuit Trims Bank’s Good Faith Defense to Fraudulent Transfer Claims
    2017-03-09

    A defendant bank (“Bank”) in a fraudulent transfer suit “could not prove” its “good faith” defense for loan repayments it received after its “investigator discovered [the] fraudulent past” of the Ponzi scheme debtor’s principal but “failed to disclose that past to [the Bank’s account] manager,” held the U.S. Court of Appeals for the Sixth Circuit on Feb. 8, 2017. Meoli v. Huntington Nat’l Bank, 2017 U.S. App. LEXIS 2248, *28 (6th Cir. Feb. 8, 2017).

    Filed under:
    USA, Banking, Insolvency & Restructuring, Litigation, White Collar Crime, Schulte Roth & Zabel LLP, Sixth Circuit, Seventh Circuit
    Authors:
    Michael L. Cook
    Location:
    USA
    Firm:
    Schulte Roth & Zabel LLP
    Lender’s Derivative Breach of Fiduciary Duty Claim Not Time-Barred Because of Its Knowledge
    2016-07-08

    A lender’s (“Lender”) derivative breach of fiduciary duty claims on behalf of Chapter 7 guarantor-Debtors cannot be time-barred because of Lender’s knowledge of the “[d]efendants’ conduct,” held the U.S. District Court for the District of Delaware on June 22, 2016. In re AMC Investors, LLC, 2016 U.S. Dist. LEXIS 80861, *16 (Del. June 22, 2016).

    Filed under:
    USA, Delaware, Banking, Insolvency & Restructuring, Litigation, Schulte Roth & Zabel LLP, Credit (finance), Surety, Breach of contract, Fiduciary, Default (finance), United States bankruptcy court
    Authors:
    Michael L. Cook
    Location:
    USA
    Firm:
    Schulte Roth & Zabel LLP
    Tenth Circuit BAP limits insider claims
    2015-12-01

    Insider creditors “waived [the] right to charge default interest on” their claims and “failed to prove” their claim for non-default interest, held the U.S. Bankruptcy Appellate Panel for the Tenth Circuit (“BAP”) on Nov. 6, 2015. In re Autterson, 2015 WL 6789168, at *4 (10th Cir. BAP, Nov. 6, 2015).

    Filed under:
    USA, Banking, Insolvency & Restructuring, Litigation, Schulte Roth & Zabel LLP, Debtor, Interest, Default (finance), United States bankruptcy court, Bankruptcy Appellate Panel, Tenth Circuit
    Authors:
    Michael L. Cook
    Location:
    USA
    Firm:
    Schulte Roth & Zabel LLP
    Lehman Brothers International (Europe) in administration: latest High Court decisions on application of surplus proceeds in the ‘Waterfall’ series of cases
    2015-08-04

    On 31 July 2015, the English High Court delivered its judgments in the ‘Waterfall IIA’ and ‘Waterfall IIB’ cases. The decisions are important to stakeholders in determining key questions about how, following payment in 2014 of all the provable claims, the estimated £7.39-billion surplus (the ‘Surplus’) in Lehman Brothers International (Europe) (in administration) (‘LBIE’) will be shared amongst them. For others, the decisions may be of general interest in probing some rarely aired legal issues relating to the lower levels of the insolvency payment waterfall.

    Filed under:
    United Kingdom, Banking, Insolvency & Restructuring, Litigation, Schulte Roth & Zabel LLP, Lehman Brothers, High Court of Justice
    Location:
    United Kingdom
    Firm:
    Schulte Roth & Zabel LLP

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