Disclosing Connections and Relationships Under Rule 2014

Journal Issue

Apr 2001

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With the ever-increasing probability of a new bankruptcy bill<a href="#1" name="1a">1</a> being enacted this
year, it appears that many new ethical issues will confront bankruptcy practitioners in
2001.<a href="#2" name="2a">2</a> However, this month's column will not speculate as to what changes the
pending legislation may bring, but instead will focus on proposed new changes to
Bankruptcy Rule 2014, which is to replace current Rule 2014, and how "new"
Rule 2014 will impact the duty of a professional to disclose his relationships and
connections. Unlike the current bankruptcy legislation, which may still yet be subject
to significant revisions, New 2014 will likely take effect in its present form in
December 2001.<a href="#3" name="3a">3</a> Although the changes to Rule 2014 are described as being made
to make Rule 2014 "conform more closely to applicable provisions of the [Bankruptcy
Code],"<a href="#4" name="4a">4</a> the changes will have an important impact on the amount and detail of
disclosure required in bankruptcy employment applications.

<h3>What Are Connections Under the Current Version of Rule 2014?</h3>

Under <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C. §327(a)</a>, in order to be employed as a professional by
a bankruptcy estate, the professional must not "hold or represent an interest adverse
to the estate" and must be "disinterested."<a href="#5" name="5a">5</a> Attorneys employed as special counsel
to the estate under <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C. §327(e)</a> and professionals employed under <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=…
U.S.C. §§1103</a> and 1104 face less stringent requirements.<a href="#6" name="6a">6</a> However, all
professionals whose employment must be approved by the bankruptcy court are required to
make disclosure under Rule 2014.

Currently, Rule 2014<a href="#7" name="7a">7</a> does not provide any limits on the disclosure of
connections related to <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C. §327</a> employment issues. Courts have generally
applied Rule 2014 broadly and have held that professionals have little discretion
in determining what is a relevant or material connection.<a href="#8" name="8a">8</a>

Rule 2014 requires disclosure of all of a professional's connections with (1) the
debtor, (2) any creditors, (3) other parties in interest, (4) the debtors,
creditors and other parties in interest's attorneys and/or accountants, and (5) the
U.S. Trustee and persons employed by the U.S. Trustee's office (collectively,
"2014 parties").<a href="#9" name="9a">9</a> Currently, courts have recognized three broad categories of
"connections"—financial, business and personal<a href="#10" name="10a">10</a>—that must be disclosed pursuant to Rule
2014.<a href="#11" name="11a">11</a>

Financial Connections. Perhaps the most common form of connection that professionals
must disclose are financial connections that the professional may have with 2014
parties. One of the first decisions that discussed the need for professionals to fully
disclose financial connections was In re Arlan's Dept. Stores Inc.,<a href="#12" name="12a">12</a> where
estate counsel was denied all compensation after, among other things, failing to
disclose that its $125,000 retainer was paid by taking almost all of the cash
receipts from the debtor's department stores.<a href="#13" name="13a">13</a>

More recently, courts have used Rule 2014 to require debtors' professionals to
disclose the sources<a href="#14" name="14a">14</a> of fee payments and/or retainers<a href="#15" name="15a">15</a> paid to the professionals.
The most important case concerning the degree of disclosure of financial connections
needed to comply with Rule 2014 is In re Park Helena Corp.<a href="#16" name="16a">16</a> In Park
Helena, the debtor's counsel received a $150,000 retainer from the debtor's
president. While counsel disclosed the retainer, they did not disclose the actual
source of the retainer until their first fee application. At that time, the debtor's
counsel disclosed that the retainer was paid by the debtor's president, but argued that
it was part of a repayment of a loan the debtor had made to the president prior to
the bankruptcy.<a href="#17" name="17a">17</a> The Ninth Circuit found that debtor's counsel violated <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=…
U.S.C. §329</a> as well as Bankruptcy Rules 2014 and 2016.<a href="#18" name="18a">18</a> In finding
a violation of Rule 2014, the Ninth Circuit held that even if the retainer was
paid from the debtor's funds, and there was no conflict of interest, the "failure
to describe the circumstances of the payment" was a violation of Rule 2014. The
Ninth Circuit ultimately denied all requested fees.<a href="#19" name="19a">19</a>

Business Connections. Courts have also determined that a professional's business
connections to 2014 parties (i.e., working for or representing a 2014 party)
are covered by Rule 2014. Courts have held that representation of an entity that
may be able to control or influence a bankruptcy estate must be disclosed.<a href="#20" name="20a">20</a> Courts
also have held that pre-petition work, which in and of itself was adverse to the
estate, must also be disclosed.<a href="#21" name="21a">21</a>

The two most famous cases involving failure to disclose business connections are
U.S. v. Gellene<a href="#22" name="22a">22</a> and In re Leslie Fay Companies Inc.<a href="#23" name="23a">23</a> In Gellene, a
bankruptcy attorney failed to disclose his representation of a large secured creditor in
a chapter 11 case in which his firm was employed as debtor's counsel and was
ultimately convicted of making false oaths in a bankruptcy proceeding.<a href="#24" name="24a">24</a> The court
found the failure to disclose this connection made the 2014 disclosure false,
notwithstanding Gellene's contentions that disclosure was not necessary.<a href="#25" name="25a">25</a>

In Leslie Fay, the debtor's counsel was sanctioned for failing to disclose their
pre-petition representation of board members and the debtor's outside auditors, who could
be sued by the debtor.<a href="#26" name="26a">26</a> The court rejected the professional's contention that no
such disclosure was necessary because counsel's investigation disclosed that neither party
would be liable to the debtor<a href="#27" name="27a">27</a> and imposed significant sanctions on the professional.

Personal Connections. The final important category of connections, which courts are
increasingly requiring to be disclosed, are personal connections. Although the full
range of personal connections between professionals and 2014 parties, which must be
disclosed, has not been fully developed,<a href="#28" name="28a">28</a> three recent cases illustrate the types
of connections that need to be disclosed.

In In re El San Juan Hotel Corp.,<a href="#29" name="29a">29</a> counsel for a successor chapter 7
trustee was denied all fees due to his failure to disclose (1) his retention, in
a separate bankruptcy case, by the previous trustee of the estate, who was ultimately
convicted of embezzlement from the bankruptcy estate, and (2) his close friendship
with the attorney who served as counsel to the previous trustee in litigation with the
current trustee.<a href="#30" name="30a">30</a>

In In re Bonneveille Pacific Corp.,<a href="#31" name="31a">31</a> counsel for the unsecured creditors'
committee resigned from the case when it was discovered that an "of counsel" attorney
with the committee and counsel were married to an insider to one of the debtor's
subsidiaries.<a href="#32" name="32a">32</a> This connection had not been previously discovered or disclosed.

Finally, in the Merry-Go-Round<a href="#33" name="33a">33</a> case, the accountant for a chapter 11 debtor
was forced to settle a lawsuit against it for $185 million. One of the reasons
for the settlement was an allegation that the accounting firm had concealed, from the
debtor and the court, various relationships, including personal relationships, that
members of the accounting firm had with the debtor's counsel, which kept the counsel
from disclosing the accountants' alleged malpractice in the debtor's case.<a href="#34" name="34a">34</a>

Is There Such a Thing as a de Minimis Connection? While cases such as In re
Park-Helena Corp.<a href="#35" name="35a">35</a> and In re Crivello36 contain sweeping dicta that all
connections, no matter how de minimis, must be fully disclosed, the holdings of
these cases and other decisions addressing Rule 2014 clearly indicate that the
"missing" disclosures were, in most cases, material<a href="#37" name="37a">37</a> to a determination of whether
a professional could be employed. This was recognized by the bankruptcy court in

In re Rusty Jones,<a href="#38" name="38a">38</a> where the noted ownership of a hot dog stand 20 years
ago by a professional and an owner of the debtor would be so de minimis that they
need not be disclosed.<a href="#39" name="39a">39</a> The Rusty Jones court noted that connections that are
either related to the bankruptcy proceedings or could "reasonably have an affect on
the attorney's judgment in the case" are the types of connections that must be
disclosed.<a href="#40" name="40a">40</a> Unfortunately, neither Rusty Jones nor any other decisions clearly define
what connections could "reasonably affect" an attorney's judgment.

<h3>New Rule 2014: Interest, Connections and Relationships</h3>

The new version of Bankruptcy Rule 2014 totally replaces current Rule 2014.
Subsection (b) covers the disclosures a professional employed under <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C.
§327, 1103</a> or 1114, and provides:
<blockquote>
The application shall be accompanied by a verified statement of the person to
be employed, made according to the best of that person's knowledge, information
and belief, formed after an inquiry reasonable under the circumstances, which
shall state: (1) that the person is eligible under the Code for employment
for the purposes set forth in the application; (2) any interest that the
person holds or represents that is adverse to the estate; (3) any interest,
connection or relationship that the person has relevant to determining whether the
person is disinterested under §101; (4) any relationship the person has with
the U.S. Trustee, or with any employee of the U.S. Trustee, for the region
in which the case is pending; (5) the information required to be disclosed
under §329(a) if the professional is an attorney; and (6) whether the
person shared or has agreed to share any compensation with any person, other
than a partner, employee or regular associate of the person to be employed, and
if so, the details.
</blockquote>

While the new version of Rule 2014 will change professional employment application
processes in a number of areas, of particular importance to this article is subsection
(b), which "limits" disclosure of connections to "interests, connections or
relationships" that are "relevant to determining whether a professional is disinterested
under [<a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C. §101</a>]."

The Rusty Jones court noted that connections
that are either related to the bankruptcy
proceedings or could "reasonably have an effect
on the attorney's judgment in the case" are the
types of connections that must be disclosed.
</center></big>
<hr>
</blockquote></blockquote>

While this language eliminates the largely theoretical questions about whether
irrelevant "hot dog stand" connections must be disclosed, it provides no guidance as
to what connections are relevant to determining whether a professional is disinterested.
New Rule 2014(b) does offer some assistance in dealing with how to make a
disclosure by indicating that a professional is required to "undertake a reasonable
inquiry under the circumstances to identify any facts relevant to that
determination."<a href="#41" name="41a">41</a>

Under new Rule 2014, professionals should take a three-step approach to making
the required Rule 2014 disclosures. First, professionals should describe, in
detail, what steps he has taken in investigating his firm connections, relationships
and interests for purposes of this Rule 2014 disclosure, including a statement that
he or she is eligible for employment under the Code.<a href="#42" name="42a">42</a> A detailed discussion of
the nature of the inquiry will greatly reduce the possibility that a court will later
determine a professional "did not look very hard" for possible conflicts, as well as
give the court, U.S. Trustee's office and other interested parties an opportunity to
immediately explore other relevant areas—rather than wait until late in the case—to
second-guess a professional's choices in investigating his firm's connections,
relationships and interests.

Second, professionals must disclose any connection, interest or relationship that they
may have with the debtor or any other party that could have some possible impact on
a court's determination of whether the professional should be employed. If there is
any doubt, disclose.<a href="#43" name="43a">43</a> At worst, you will not be employed, but in those
circumstances disclosure is clearly required. At best, the issue will be fully and
finally resolved before expending a great deal of time and expense have been put into
the case.

Finally, professionals are advised to describe any particular interest, connection
or relationship in some detail. Boilerplate statements that "you represent various
creditors of the debtor in other non-related matters" is in some respects worse than
no disclosure, as the court and other parties' view of what is trivial or unimportant
representations may vary greatly from the view of the disclosing professionals. The
detail given in a disclosure under either new or old Rule 2014 must at least be
sufficient to put the court and other parties on notice as to what ethical issues may
be involved in a particular connection or relationship.<a href="#44" name="44a">44</a>

<h3>Conclusion</h3>

New Rule 2014 is clearly a step in the right direction to simplify disclosure
in employment applications, as it attempts to limit and clarify what interests,
connections and relationships must be disclosed. Unfortunately, this additional
clarification does not resolve a number of key issues, including what is a relevant
interest, connection or relationship and how much disclosure is needed to meet New Rule
2014's requirements. It will be left to courts to answer those questions when
(and if) New Rule 2014 enters the world of Bankruptcy Rules.

<hr>
<h3>Footnotes</h3>

<a name="1">1</a> As of March 15, the House and Senate had both passed their own versions (H.R. 333, S. 420)of the new bankruptcy
bill, with conference of the two bills pending. President Bush is expected to sign either version of the new bankruptcy bill. <a href="#1a">Return to article</a>

<a name="2">2</a> A future column (or columns) will address the various new ethical issues that will arise as a result of the new bankruptcy law. <a href="#2a">Return to article</a>

<a name="3">3</a> While almost all formally proposed amendments to the Bankruptcy Rules are ultimately enacted, all bankruptcy attorneys remember the
fate of the infamous "litigation package" of Bankruptcy Rule amendments that were withdrawn from consideration due to widespread protest. <a href="#3a">Return to article</a>

<a name="4">4</a> Report of the Advisory Committee on Bankruptcy Rules to Committee on Rules of Practice and Procedure of the Judicial Conference
of the United States (May 11, 2000). <a href="#4a">Return to article</a>

<a name="5">5</a> See <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C. §101(14)</a> (definitions of disinterested person). <a href="#5a">Return to article</a>

<a name="6">6</a> See <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C. §§327(e), 1103</a> and 1104. <a href="#6a">Return to article</a>

<a name="7">7</a> Rule 2014. Employment of Professional Persons
<blockquote>
(a) Application for an order of employment: An order approving the employment of attorneys, accountants, appraisers, auctioneers,
agents or other professionals pursuant to §§327, 1103 or 1114 of the Code shall be made only on application of the trustee
or committee. The application shall be filed and, unless the case is a chapter 9 municipality case, a copy of the application shall
be transmitted by the applicant to the U.S. Trustee. The application shall state the specific facts showing the necessity for the
employment, the name of the person to be employed, the reasons for the selection, the professional services to be rendered, any
proposed arrangement for compensation and, to the best of the applicant's knowledge, all of the person's connections with the debtor,
creditors, any other party in interest, their respective attorneys and accountants, the U.S. Trustee, or any person employed in the
office of the U.S. Trustee. The application shall be accompanied by a verified statement of the person to be employed, setting forth
the person's connections with the debtor, creditors, any other party in interest, their respective attorneys and accountants, the U.S.
Trustee or any person employed in the office of the U.S. Trustee. <a href="#7a">Return to article</a>
</blockquote>

<a name="8">8</a> See, generally, <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Crivello, 134 F.3d 831 (7th Cir. 1998)</a>; <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Park-Helena Corp., 63 F.3d 877
(9th Cir. 1995)</a>; <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… v. Braunstein, 19 F.3d 54 (1st Cir. 1994)</a>. <a href="#8a">Return to article</a>

<a name="9">9</a> For an excellent discussion of the scope of disclosure required of professionals seeking approval of their employment by a bankruptcy court,
see Rapaport, Nancy B., "Avoiding Judicial Wrath: The 10 Commandments for Bankruptcy Practitioners," 5 J. Bankr. L. & P. 615
(1996) [hereinafter "10 Commandments"]. <a href="#9a">Return to article</a>

<a name="10">10</a> These categories are solely the creation of the author, and there is a great deal of overlap between each group. Further, there are
some connections that fall outside these categories. See <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… v. First NH Mortgage Corp., 200 F.3d 30, 37 (1st Cir.
1999)</a> (professional failed to disclose that it had a possible conflict of interest under state code of professional conduct). <a href="#10a">Return to article</a>

<a name="11">11</a> See "10 Commandments" at 619-622. <a href="#11a">Return to article</a>

<a name="12">12</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… F.2d 925. (2d Cir. 1979)</a>. <a href="#12a">Return to article</a>

<a name="13">13</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=…; at 935</a>. See, also, <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Burke, 147 B.R. 787 (Bankr. N.D. Okla. 1992)</a> (debtor's attorney took all of
the debtor's funds for retainer, which resulted in the starvation of the debtor's cattle herd). <a href="#13a">Return to article</a>

<a name="14">14</a> See <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Park Helena Corp., 63 F.3d 877 (9th Cir. 1995)</a>; <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Smitty's Truck Stop Inc., 210 B.R. 844
(10th Cir. B.A.P. 1997)</a>. <a href="#14a">Return to article</a>

<a name="15">15</a> See <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Downs, 103 F.3d 472, 478 (6th Cir. 1996)</a>. <a href="#15a">Return to article</a>

<a name="16">16</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… F.3d 877</a>. <a href="#16a">Return to article</a>

<a name="17">17</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=…; at 881</a>. <a href="#17a">Return to article</a>

<a name="18">18</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=…; at 882</a>. <a href="#18a">Return to article</a>

<a name="19">19</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=…; <a href="#19a">Return to article</a>

<a name="20">20</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Crivello, 134 F.3d 831 (7th Cir. 1998)</a>; <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re EWC Inc., 138 B.R. 276 (Bankr. W.D. Okla.
1992)</a>. <a href="#20a">Return to article</a>

<a name="21">21</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Southern Kitchens Inc., 216 B.R. 819 (Bankr. D. Minn. 1998)</a>; <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Amdura Corp., 139 B.R. 963
(Bankr. D. Colo. 1992)</a>. <a href="#21a">Return to article</a>

<a name="22">22</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… F.3d 578 (7th Cir. 1999)</a>. <a href="#22a">Return to article</a>

<a name="23">23</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… B.R. 525 (Bankr. S.D.N.Y. 1994)</a>. <a href="#23a">Return to article</a>

<a name="24">24</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… F.3d at 585</a>. <a href="#24a">Return to article</a>

<a name="25">25</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=…; at 591-93</a>. <a href="#25a">Return to article</a>

<a name="26">26</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… B.R. at 553</a>. <a href="#26a">Return to article</a>

<a name="27">27</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=…; <a href="#27a">Return to article</a>

<a name="28">28</a> See, generally, <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Bennett Funding Group Inc., 226 B.R. 331 (Bankr. N.D.N.Y. 1998)</a> (requiring disclosure
of details of clients of accounting firms for which trustee provided regulatory and legislative advice); <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Cody, 122 B.R. 520
(Bankr. N.D. Ohio 1990)</a> (failure to disclose attorney shared office space with creditors' attorney). <a href="#28a">Return to article</a>

<a name="29">29</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… B.R. 635 (1st Cir. B.A.P. 1999)</a>. <a href="#29a">Return to article</a>

<a name="30">30</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=…; at 639</a>. <a href="#30a">Return to article</a>

<a name="31">31</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… B.R. 868 (Bankr. D. Utah 1996)</a>. <a href="#31a">Return to article</a>

<a name="32">32</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=…; at 879</a>. <a href="#32a">Return to article</a>

<a name="33">33</a> See, generally, <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Merry-Go-Round Enterprises Inc., 222 B.R. 254 (D. Md. 1998)</a>. <a href="#33a">Return to article</a>

<a name="34">34</a> See "Ernst Pact Spells Caution in Bankruptcy," New York L.J. (May 6, 1999); "$185 Million Suit by Former Client Could
Probe Bounds of Bankruptcy Law and Legal Ethics," Legal Times (March 20, 2000). <a href="#34a">Return to article</a>

<a name="35">35</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… F.3d 877 (9th Cir. 1995)</a>. <a href="#35a">Return to article</a>

<a name="36">36</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… F.3d 831 (7th Cir. 1998)</a>. <a href="#36a">Return to article</a>

<a name="37">37</a> See, generally, "10 Commandments" at 619-622. <a href="#37a">Return to article</a>

<a name="38">38</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… B.R. 321 (Bankr. N.D. Ill. 1991)</a>. <a href="#38a">Return to article</a>

<a name="39">39</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=…; at 346</a>. <a href="#39a">Return to article</a>

<a name="40">40</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=…; <a href="#40a">Return to article</a>

<a name="41">41</a> See Committee Note to proposed Rule 2014 of Rules of Bankruptcy Procedure. <a href="#41a">Return to article</a>

<a name="42">42</a> Proposed Rule 2014(b)(1) of the Rules of Bankruptcy Procedure. <a href="#42a">Return to article</a>

<a name="43">43</a> "10 Commandments" at 619-622. <a href="#43a">Return to article</a>

<a name="44">44</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Crivello, 134 F.3d at 831</a>; <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… re Park Helena Corp., 63 F.3d at 877</a>. <a href="#44a">Return to article</a>

Journal Authors

C. R. Bowles

Journal Date

Sunday, April 1, 2001 - 12:00

Bankruptcy Rule

2001