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Second, Fifth, Ninth and Eleventh Circuits agree that supplying “necessaries” by itself won’t justify a maritime lien.

Ninth Circuit is hesitant to make bankruptcy time deadlines jurisdictional.

Corporate debtors anticipating disputes with secured lenders have a good reason for filing chapter 11 in California, assuming there is no need for an injunction barring suit against a
non-bankrupt third party.

The Ninth Circuit quickly rectifies its own mistake by allowing creditors to recover counsel fees in suits to recover damages for automatic stay violations.