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Following a suggestion made by two Supreme Court justices, Tribune creditors ask the Second Circuit to recall the mandate and remand for reconsideration in district court.

Two justices recommend that the Second Circuit reconsider the ‘Tribune’ safe harbor decision in light of Merit Management.

Bankruptcy Judge Vyskocil holds that alter ego need not be alleged to recover from a corporation’s sole shareholder as the beneficiary of a fraudulent transfer.

Intermediate transfers to financial institutions do not trigger the safe harbor.