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    When goods are shipped from overseas, when are they considered “received by the debtor” for purposes of asserting a section 503(b)(9) administrative claim?
    2014-08-05

    A bankruptcy court in Pennsylvania recently held that trade creditors who supplied goods to a debtor prior to its bankruptcy filing were not entitled to administrative priority status under Bankruptcy Code section 503(b)(9) because the goods were “received by the debtor” at the time they were placed on the vessel at the port overseas more than 20 days before the debtor’s bankruptcy filing, although the debtor took possession of the goods within the 20 day period.  In re World Imports, Ltd. — B.R. —-, 2014 WL 2750258 (Bankr. E.D. Pa., June 18, 2014).

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Trade & Customs, Sheppard Mullin Richter & Hampton LLP, Debtor, United States bankruptcy court
    Authors:
    Robert Sahyan
    Location:
    USA
    Firm:
    Sheppard Mullin Richter & Hampton LLP
    Effectiveness of reaffirmation agreements
    2014-08-06

    Reaffirmation agreement becomes effective upon filing with the Court if represented by an attorney and not presumed an undue hardship.  Per the reaffirmation agreement language set out in the Code, “…No court approval is required if your reaffirmation agreement is for a consumer debt secured by a mortgage, deed of trust, security deed, or other lien on your real property, like your home.”  § 524(k)(3)(J)(i)7.

    Filed under:
    USA, Banking, Insolvency & Restructuring, Litigation, Real Estate, Rogers Townsend & Thomas PC, In rem jurisdiction
    Authors:
    Neil D. Jonas
    Location:
    USA
    Firm:
    Rogers Townsend & Thomas PC
    Southern District of New York holds in Madoff that the Bankruptcy Code cannot be used to recover extraterritorial transfers
    2014-08-06

    Dealing a major blow to the trustee’s efforts to recover fraudulent transfers on behalf of the bankruptcy estate of the company run by Bernard Madoff, Judge Jed S. Rakoff of the United States District Court for the Southern District of New York held in SIPC v. Bernard L. Madoff Investment Securities LLC1 that the Bankruptcy Code cannot be used to recover fraudulent transfers of funds that occur entirely outside the United States.

    Filed under:
    USA, New York, Capital Markets, Insolvency & Restructuring, Litigation, White Collar Crime, A&O Shearman, Extraterritoriality, Title 11 of the US Code
    Authors:
    Douglas P. Bartner , Solomon J. Noh , Fredric Sosnick , Ned S. Schodek
    Location:
    USA
    Firm:
    A&O Shearman
    Genco: future earnings? That was then; this is now
    2014-08-06

    Bankruptcy courts typically rely on three valuation methods to determine a debtor’s enterprise value: comparable company analysis, precedent transaction analysis, and discounted cash flow analysis.

    Filed under:
    USA, New York, Insolvency & Restructuring, Litigation, Shipping & Transport, Weil Gotshal & Manges LLP, Debtor, Valuation (finance)
    Authors:
    Gabriel A. Morgan
    Location:
    USA
    Firm:
    Weil Gotshal & Manges LLP
    The Texas Supreme Court decision in Ritchie v. Rupe
    2014-08-01

    On June 20, 2014, the Texas Supreme Court issued its opinion in Ritchie v. Rupe, 2014 Tex. LEXIS 500 (Tex. 2014). In Ritchie, a minority shareholder in a closely held corporation attempted to force the majority shareholders to buy-out the minority shareholder’s interest in the corporation by bringing a claim of shareholder oppression under § 11.404 of the Texas Business Organizations Code (TBOC), the Texas receivership statute.

    Filed under:
    USA, Texas, Company & Commercial, Insolvency & Restructuring, Litigation, Akin Gump Strauss Hauer & Feld LLP, Shareholder, Business judgement rule, Texas Supreme Court
    Authors:
    Lisa A. Peterson , John Patrick Clayton
    Location:
    USA
    Firm:
    Akin Gump Strauss Hauer & Feld LLP
    Post-petition interest: default rate is not a slam dunk
    2014-08-01

    In re Residential Capital, LLC, 508 B.R. 851 (Bankr. S.D.N.Y. 2014) –

    An oversecured creditor claimed post-petition interest at the contract default rate. The debtors and the post-confirmation liquidating trust objected, arguing that the lender should be limited to the non-default rate.

    Filed under:
    USA, New York, Insolvency & Restructuring, Litigation, Troutman Pepper, Debtor, Interest, Default (finance)
    Location:
    USA
    Firm:
    Troutman Pepper
    Class certification granted to former MF Global employees seeking vacation pay
    2014-08-01

    Judge Glenn of the U.S. Bankruptcy Court for the Southern District of New York recently granted class claim certification to a group of former MF Global employees seeking payment on account of unpaid accrued vacation time. 

    Filed under:
    USA, New York, Employment & Labor, Insolvency & Restructuring, Litigation, Cooley LLP, United States bankruptcy court
    Location:
    USA
    Firm:
    Cooley LLP
    Report from the BHBA’s review of the three bankruptcy-related Supreme Court decisions
    2014-08-01

    The Beverly Hills Bar Association’s Bankruptcy Section recently held a program discussing the three recent bankruptcy-related Supreme Court decisions: Law v.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Greenberg Glusker Fields Claman & Machtinger LLP
    Location:
    USA
    Firm:
    Greenberg Glusker Fields Claman & Machtinger LLP
    CFPB, state AGs announce joint enforcement action against military consumer lender
    2014-08-01

    On July 29, the CFPB and 13 state AGs announced a consent order that requires a consumer lender currently in Chapter 7 bankruptcy to provide $92 million in debt relief for about 17,000 U.S.

    Filed under:
    USA, Banking, Insolvency & Restructuring, Orrick, Herrington & Sutcliffe LLP, Consumer Financial Protection Bureau (USA)
    Location:
    USA
    Firm:
    Orrick, Herrington & Sutcliffe LLP
    Plaintiffs seek U.S. Supreme Court review of diacetyl ruling
    2014-08-01

    In a petition for a writ of certiorari, plaintiffs alleging harm by exposure to the flavoring agent diacetyl have argued that the Third Circuit erred in ruling that Aaroma Holdings cannot be held liable for the actions of diacetyl producer Emoral Inc., which Aaroma purchased following the alleged exposures. Diacetyl Plaintiffs v. Aaroma Holdings, No. 14-71 (U.S., petition for writ of certiorari filed July 18, 2014).

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Shook Hardy & Bacon LLP, Third Circuit
    Authors:
    Mark D. Anstoetter , Madeleine M. McDonough
    Location:
    USA
    Firm:
    Shook Hardy & Bacon LLP

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