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Recent Decision Holds Bankruptcy Courts May Independently Grant Nonconsensual Third-Party Releases to Enforce Foreign...

On April 21, 2025, Chief Judge Martin Glenn of the U.S. Bankruptcy Court for the Southern District of New York issued a memorandum opinion in In re Odebrecht Engenharia e Construção S.A., Case No. 25-10482 (MG), addressing...more

Creditors May Take Rule 2004 Examinations in Chapter 15 Cases

A recent Bankruptcy Court decision indicates that Rule 2004—a powerful information-gathering tool that has long been utilized by foreign representatives in chapter 15 cases—may also be used by creditors in appropriate...more

Landmark Ninth Circuit Decision on Post-Petition Interest for Unimpaired Creditors of a Solvent Chapter 11 Debtor

The Ninth Circuit became the first circuit-level court to address the correct rate of interest for unimpaired, unsecured creditors of a solvent chapter 11 debtor. The Ninth Circuit held that the common law “solvent debtor...more

Third Circuit Confirms Triangular Setoffs Unenforceable in Bankruptcy

The Third Circuit’s recent decision in In re Orexigen Therapeutics Inc., 990 F.3d 748 (3d Cir. 2021) holds that section 553 of the Bankruptcy Code, which governs creditor setoffs, requires “strict bilateral mutuality.” As a...more

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