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When It Counts: Fully Secured and Paid-Off Creditors Can Count as Petitioning Creditors for Involuntary Bankruptcy Petitions

In a recent pair of decisions, the Ninth Circuit Bankruptcy Appellate Panel held that even fully secured creditors with nonrecourse claims and unsecured creditors who are paid off after the involuntary petition may qualify as...more

U.S. Bankruptcy Court Holds that State-Court Receivership Order Does Not Bar Managing Member from Seeking LLC Bankruptcy Relief

A typical receivership order does not limit the ability of a managing member to seek limited liability company bankruptcy relief for distressed real estate or other enterprises. An enterprise, even if in receivership,...more

Not So Fast: An Option to Purchase Real Estate May Not Always Be Rejected by the Debtor in Bankruptcy

A recent bankruptcy court decision determined that a debtor cannot reject an unexercised option for the purchase of its real estate, raising a potentially significant bar to any debtor extricating itself from an under-market...more

U.S. District Court in Connecticut Navigates Supreme Court Precedent Barring Recovery of Certain Postpetition Default Interest

An oversecured creditor can recover default interest where the sole default trigger was the borrower’s bankruptcy filing after considering all relevant equitable considerations. While Bankruptcy Code section 506(b)...more

Time Approach Applied to Cap Rent Claim in Century 21 Bankruptcy Cases

New York bankruptcy court breaks with precedent and endorses time approach for calculating lease termination damages over rent amount approach, resulting in smaller claims for landlords. Time approach limits, and often...more

Subchapter V Alert–Congress Begins Legislative Action to Extend $7.5 Million Debt Ceiling, Which Remains Set to Expire on March...

Congress introduces legislation to extend the $7.5 million debt ceiling for Subchapter V eligibility for an additional year to March 27, 2022. Subchapter V was designed to be a cost-effective distress tool for small...more

Bankruptcy Code Amendments Aimed at Allowing Extended Rent Holidays for Small Business Debtors Pose More Questions Than They...

While the recent Bankruptcy Code amendments allow small business debtors to extend their deferral of lease obligations beyond the first 60 days of the bankruptcy case, the amendments raise and leave unanswered important...more

Bankruptcy Court Denies Retail Debtor’s State-Law Based Arguments to Avoid Paying Rent During Chapter 11

A recent Chuck E. Cheese decision rejects the debtor’s/tenant’s request to avoid paying rent based upon state law equity arguments. CEC’s leases expressly do not permit rent relief even if force majeure is triggered....more

Bankruptcy Court Rules Bankruptcy Code Does Not Permit Extended Rent Holiday for Retail Debtors

A recent Chuck E. Cheese decision denies the debtor’s/tenant’s request to defer paying rent after the 60-day “rent holiday.” The Bankruptcy Court applied the “plain language” rule to hold that section 365(d)(3)’s rent...more

The Letter of Credit Conundrum: When a Debtor’s Default May Be Preferable to Its Late Payment

“Can an unsecured creditor be better off when the debtor defaults rather than paying off the debt? Yes: Law can be stranger than fiction in the Preference Zone.”—Ninth Circuit Untimely payment by tenants and other obligors...more

Personal Guaranties May Not Deter Property Owner Bankruptcies

Lenders should plan for real estate owner bankruptcies despite having a non-recourse carveout guaranty triggered by the owner’s bankruptcy filing. Real estate bankruptcies may occur despite personal guaranties because...more

How Chapter 11 Solved One Multifamily Condo Regime’s Dual Challenges of Mounting Liabilities and Unpaid Dues

Multifamily condominium regimes with mounting liabilities and unpaid dues during COVID-19 may find answers in bankruptcy to the obstacles posed by individually titled units. We created and implemented a strategy that allowed...more

SCOTUS to Review Constitutionality of Puerto Rico’s Oversight Board

High Court review threatens to unravel Puerto Rico’s Title III bankruptcy cases. The U.S. Supreme Court has agreed to review the First Circuit’s ruling invalidating the appointment of the members of the Puerto Rico...more

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