Rosanne Ciambrone

Rosanne Ciambrone

Duane Morris LLP

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Second Circuit's Significant Decision Could Impact Liquidating Trustees

In the case of United States of America v. Edward P. Bond, No. 12-4803 (2d. Cir. August 13, 2014), the United States Court of Appeals for the Second Circuit (the "Second Circuit") issued a decision that could have...more

8/29/2014 - Chapter 11 Commercial Bankruptcy Liquidation Trustees Trusts

Bitcoin Exchange Mt. Gox Files for Bankruptcy Protection; May Have Broader Implications for Digital Currency Industry

On February 28, 2014, international Bitcoin exchange Mt. Gox filed for bankruptcy protection in Tokyo, capping what is likely the most tumultuous month yet in the history of the controversial virtual currency. Mt. Gox—the...more

3/4/2014 - Bitcoins Mt.Gox Virtual Currency

Proceed with Caution When Foreclosing in Washington State: Split Decisions Regarding Deficiency Claims

Last week, the Washington Court of Appeals, Division One, ruled that, notwithstanding the anti-deficiency provision in the state's Deeds of Trust Act, a lender can pursue a deficiency judgment against a guarantor following a...more

2/27/2014 - Anti-Deficiency Provisions Foreclosure Mortgages

Bankruptcy Appellate Panel for Eighth Circuit Reaffirms It Is Not the Forum for Debtors in Pending Bankruptcy Cases to Take Second...

Last week, the United States Bankruptcy Appellate Panel for the Eighth Circuit (8th Circuit B.A.P.) reaffirmed that debtors in pending bankruptcy cases may not use the bankruptcy court as a forum for a second bite at the...more

2/24/2014 - Behrens v. United States Consumer Bankruptcy Criminal Prosecution SEC

Second Circuit Ruling Appears to Limit Ability of U.S. Bankruptcy Courts to Assist Foreign Debtors

In Drawbridge Special Opportunities Fund LP v. Barnet (In re Barnet), Case No. 13-612, 2013 WL 6482499 (2d Cir. Dec. 11, 2013), the United States Court of Appeals for the Second Circuit held that in order for a foreign...more

12/18/2013 - Chapter 15 Commercial Bankruptcy Debtors Foreign Nationals

Glaski Decision Appears to Place Lenders on Notice to Verify Accuracy and Effectiveness of Loan Assignments

The recent decision in Glaski v. Bank of America, National Association, et al., 160 Cal. Rptr. 3d 449 (2013), may, at least in certain circumstances, impact the ability of residential mortgage-backed security and commercial...more

9/10/2013 - Assignments Bank of America Lenders Mortgage-Backed Securities Mortgages Notice Requirements Servicing Agreements

U.S. Supreme Court Resolves Circuit Split in Bullock v. BankChampaign, N.A.

One of the primary purposes of bankruptcy is to provide for the discharge of certain debts in order to enable a debtor to obtain a "fresh start" post-bankruptcy. Notwithstanding this specific purpose, section 523 of Title 11...more

6/25/2013 - Debtors Defalcation Exception Dischargeable Debts Embezzlement Fiduciary Duty Fraud Larceny SCOTUS Split of Authority Trustees

Second Circuit Establishes Relevant Time Period for "Center of Main Interests" Determination Under Chapter 15 of the Bankruptcy...

In Morning Mist Holdings Limited v. Krys (In re Fairfield Sentry Limited), Case No. 11-4376, 2013 WL 1593348 (2d Cir. April 16, 2013), the United States Court of Appeals for the Second Circuit (the "Second Circuit") held that...more

4/29/2013 - Center of Main Interests Chapter 15 Debtors Insolvency

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