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How Safe Is Your 363(m) Sale? The Supreme Court’s Invalidation of Statutory Mootness is a Risk to Asset Purchasers Seeking...

On April 19, 2023, Justice Ketangi Brown Jackson, writing for a unanimous Court in MOAC Mall Holdings LLC v. Transform Holdco LLC et.al., 598 U.S. ___ 143 S. Ct. 927 (2023), held that Bankruptcy Code section 363(m) is not...more

Who Can Be A Future Claims Representative In The Third Circuit?

Imerys Talc American, Inc. (“Imerys”) filed bankruptcy in response to crushing liability imposed by mounting asbestos and talc personal injury claims to take advantage of Bankruptcy Code § 524(g) which, among other things,...more

Bifurcated Fee Agreements Approved in Southern District of Florida, But Barred in Western District of Kentucky

The United States Supreme Court ruled that 11 U.S.C. § 330(a)(1) does not authorize compensation to debtors’ attorneys from estate funds. Lamie v. U.S. Trustee, 540 U.S. 1023 (2004). A chapter 7 lawyer cannot look to the...more

COMPLIANCE WITH OFFICIAL BANKRUPTCY FORM 105 SATISFIES ASHCROFT V. IQBAL

Section 11 of Official Bankruptcy Form 105, Involuntary Petition Against an Individual, provides: Allegation- Each petitioner is eligible to file this petition under 11 U.S.C. § 303(b). The debtor may be the...more

You Have to Follow the Rules: The Importance of Adhering to Bankruptcy Rule 2002 When Serving Claims Bar Date Notices

A Delaware bankruptcy court recently held that the bar date for filing proofs of claim cannot be enforced against a creditor if the notice of the bar date was not sent by mail to that creditor. In re Cyber Litigation Inc.,...more

The Third Circuit, Latent Tort Claims And Bankruptcy Code § 524(g)

To give a reorganized debtor a “fresh start,” the Bankruptcy Code provides that the confirmation of a plan discharges the debtor from any debt that arose before the confirmation date. However, if a potential claimant lacks...more

Eleventh Circuit Holds “New Value” Need Not Remain Unpaid

One of the commonly asserted defenses to preference avoidance actions is the “new value” defense set forth in 11 U.S.C. § 547(c)(4). One issue considered by courts is whether the “new value” must remain unpaid. In a recent...more

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