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ABI Journal

Rochellel's Daily Wire

September 18, 2020

Ninth Circuit Reiterates Its Idiosyncratic Recoupment Standard

Ninth Circuit abjures bright lines in favor of a flexible approach to defining recoupment.

9th Circuit

September 17, 2020

District’s Model Chapter 13 Plan Violates the Code by Requiring More than 60 Payments

Detroit’s Judge Randon holds that a chapter 13 plan’s five-year duration begins to run from the first payment, not from confirmation.

6th Circuit, Michigan, Michigan Eastern District

September 16, 2020

A Credit Bid Doesn’t Cap the Value of a Secured Lender’s Collateral

Delaware district judge holds that the final bid at auction, not the lender’s last credit bid, fixes the value of the lender’s collateral.

3rd Circuit, Delaware

September 15, 2020

New York Judge Nixes $2.45 Billion in DIP Financing as a Sub Rosa Plan

Even though the price and terms were ‘entirely fair,’ Bankruptcy Judge Garrity disapproved DIP financing that would have locked in the right of controlling shareholders to purchase new stock at a 20% discount.

2nd Circuit, New York, New York Southern District

September 14, 2020

University Medical Unscathed After Denby-Peterson, Delaware District Judge Says

The government lost a winnable appeal by failing to present evidence in bankruptcy court.

3rd Circuit, Delaware

September 11, 2020

Rejection Didn’t Rescind Sale of Future Credit Card Receivables, New York Judge Says

Bankruptcy Judge Glenn hints that the lenders and the debtor should mediate tough questions about the enforceability of a $150 million ‘sale’ of future credit card receivables.

2nd Circuit, New York, New York Southern District

September 10, 2020

Student Loan Servicer Sanctioned $378,000 for Civil Contempt by New York Judge

Bankruptcy Judge Martin Glenn imposed civil contempt sanctions for ignoring court orders over five years.

2nd Circuit, New York, New York Southern District

September 09, 2020

Undisclosed Fee Sharing Results in Disqualification and Disgorgement in Delaware

Since they weren’t bankruptcy lawyers, the firm wasn’t disqualified for the first nondisclosure offense. The second time, Delaware’s Judge Dorsey ordered disqualification and disgorgement

3rd Circuit, Delaware

September 08, 2020

Ninth Circuit: Government Doesn’t Pay Counsel Fees on Reversal of Sua Sponte Actions

Will there be occasions where the government must pay a debtor’s counsel’s fees when a U.S. Trustee unsuccessfully opposes a debtor’s initiative?

9th Circuit

September 04, 2020

Not All Student Loans Are Nondischargeable, Tenth Circuit Holds

Tenth Circuit joins the Fifth Circuit by holding that student loans are not ‘educational benefits’ under Section 523(a)(8)(A)(ii).

10th Circuit