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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
    Delaware Bankruptcy Court Declines to Follow Second Circuit and Holds Safe Harbors Do Not Apply to Some State Law Fraudulent Conveyance Claims
    2016-07-21

    The Bankruptcy Court for the District of Delaware recently held that the Bankruptcy Code Section 546(e) safe harbors do not prevent a liquidation trust from pursuing some state law constructive fraudulent conveyance claims assigned to the trust by creditors.1 Notably, the Bankruptcy Court declined to follow the Second Circuit's recent Tribune decision, in which the Second Circuit concluded that the Section 546(e) safe harbors apply to state law constructive fraudulent conveyance claims on federal preemption grounds.2 Instead, the Bankruptcy Court decided that federal preemption did not appl

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Hunton Andrews Kurth LLP, Federal preemption, Security (finance), Safe harbor (law), Commodity broker, Foreclosure, Liquidation, Bad faith, Conveyancing, US Code, Title 11 of the US Code, Trustee, Second Circuit, United States bankruptcy court, US District Court for District of Delaware
    Authors:
    Jason W. Harbour
    Location:
    USA
    Firm:
    Hunton Andrews Kurth LLP
    Life Settlement Investments: Avoiding the Pitfalls in the Event the Life Settlement Company Files for Bankruptcy
    2016-07-18

    For those who may be considering an investment in life settlements (see my previous blog for background), recent bankruptcy filings of life settlement entities have raised a concern not often considered when determining whether or not to invest: what would happen if the entity that owns or manages the underlying insurance policy(s) ends up in bankruptcy. Life settlement companies typically include provisions in their purchase agreements that downplay the potential ramifications of a bankruptcy filing.

    Filed under:
    USA, Insolvency & Restructuring, Insurance, Berger Singerman LLP, Bankruptcy, Unsecured debt, Beneficiary, Unsecured creditor
    Authors:
    Deborah B. Talenfeld
    Location:
    USA
    Firm:
    Berger Singerman LLP
    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)
    Curing Substantive Ambiguities in Debt Documentation (and More)
    2016-07-19

    Virtually all public indentures contain provisions allowing the issuer to cure ambiguities and make other technical changes to the debt documentation without debtholder consent. When the purported ambiguities have substantive consequences, however, issuers may not be able to get away with an amendment that lacks debtholder approval. InGSO Coastline Credit Partners L.P. v. Global A&T Electronics Ltd. (NY App. Div. 1st Dept. May 3, 2016), a New York lower court bought into a “cure of ambiguity” argument and on that basis granted a motion to dismiss.

    Filed under:
    USA, Banking, Insolvency & Restructuring, Litigation, Kramer Levin Naftalis & Frankel LLP, Shareholder, Credit (finance), Collateral (finance), Covenant (law), Debt, Line of credit, Secured loan
    Location:
    USA
    Firm:
    Kramer Levin Naftalis & Frankel LLP
    The Little Airline That Couldn’t
    2016-07-19

    Remember Sabena, the ill-fated Belgian airline that declared bankruptcy in 2001? Well, to quote Ford Madox Ford, this is the saddest story I have ever heard.

    Filed under:
    USA, Aviation, Banking, Insolvency & Restructuring, Trade & Customs, White Collar Crime, Bryan Cave Leighton Paisner (Bryan Cave), Bankruptcy, Beneficiary, Office of Foreign Assets Control (USA), Deutsche Bank, Uniform Commercial Code (USA)
    Authors:
    Robert Clifton Burns
    Location:
    USA
    Firm:
    Bryan Cave Leighton Paisner (Bryan Cave)
    District Court Denys Interlocutory Appeal of Protective Order
    2016-07-19

    In the latest decision to emanate from the Madoff bankruptcy, the United States District Court for the Southern District of New York denied the appeal of a protective order that relieved Irving Picard—the court-appointed trustee—from answering discovery requests regarding his compensation arrangement with his law firm.

    Filed under:
    USA, New York, Insolvency & Restructuring, Litigation, Weil Gotshal & Manges LLP, Bankruptcy, Injunction, Discovery, Due process, Liquidation, Substantial similarity, Due Process Clause, Trustee, United States bankruptcy court
    Location:
    USA
    Firm:
    Weil Gotshal & Manges LLP
    Eleventh Circuit Holds Bankruptcy Rules Applicable to Matters on Which the Reference has been Withdrawn to the U.S. District Court
    2016-07-19

    When an adversary proceeding is transferred to the district court pursuant to a withdrawal of the reference, which rules—and deadlines—apply: those contained within the Federal Rules of Civil Procedure, or those contained within the Federal Rules of Bankruptcy Procedure? The Eleventh Circuit recently held the Federal Rules of Bankruptcy Procedure, not the Federal Rules of Civil Procedure, govern adversary proceedings before the district courts. Rosenberg v. DVI Receivables XIV, LLC, 2016 WL 1392642 (11th Cir. 2016).

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Holland & Hart LLP, Punitive damages, Bankruptcy, Federal Reporter, US Code, United States bankruptcy court, Eleventh Circuit, Third Circuit, Fourth Circuit, Seventh Circuit
    Location:
    USA
    Firm:
    Holland & Hart LLP

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