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At vero eos et accusamus et iusto odio dignissimos ducimus qui blanditiis praesentium voluptatum deleniti atque corrupti quos dolores et quas molestias excepturi sint occaecati cupiditate non provident, similique sunt in culpa qui officia deserunt mollitia animi, id est laborum et dolorum fuga. Et harum quidem rerum facilis est et expedita distinctio. Nam libero tempore, […]


On the other hand, we denounce with righteous indignation and dislike men who are so beguiled and demoralized by the charms of pleasure of the moment, so blinded by desire, that they cannot foresee the pain and trouble that are bound to ensue; and equal blame belongs to those who fail in their duty through […]

Trustee’s Use of Net Investment Method Preferred In Calculating Net Equity of the Customers in the Madoff Ponzi Scheme

April 15, 2022, New York – The District Court for the Southern District of New York has held in favor of the Trustee’s motion to avoid and recover “approximately $16,880,000 that was transferred by BLMIS (Bernard L. Madoff Investment Securities LLC) to the entity defendants, Sage Associates and Sage Realty (“Sage Accounts”), in the two […]

Sixth Circuit – Unsigned Promissory Notes Have Little Probative Value & Limited Admissibility as Evidence

September 8, 2021, Eastern District of Michigan – Debtor Oakland Physicians Medical Center, L.L.C., d/b/a Doctors’ Hospital of Michigan (represented by Trustee Basil Simon, collectively hereinafter “Debtor”) filed for Chapter 11 Bankruptcy in 2015. One of Debtor’s member-physicians, Defendant-Appellant Michael Short filed a proof of claim for $952,377.80 that he alleged he advanced to Debtor as […]

Delaware Bankruptcy Court Grants Defendants’ Motion to Dismiss As Claims Were Time-Barred Under DUFTA

August 20, 2021, District of Delaware – Plaintiff Trustee George L. Miller, for the jointly administered bankruptcy estates of the Debtors J&M Sales, Inc. filed an adversary alleging that the Debtors’ owners (‘Fallas’) operated and controlled a vast enterprise of entities that functioned as the alter-egos of the Debtors, and used the Debtors to sustain […]

A Florida Court Rules in Favor of a Title Insurance Company Because Plaintiff Failed to Meet His Burden of Proof on Issue of Reasonably Equivalent Value

The Court ruled that a debtor's transfer of assets to a defendant was not avoidable as a fraudulent transfer under 11 U.S.C.S. § 548 and Fla. Stat. §§ 726.105, 726.106, because the debtor transferred tangible assets in exchange for the defendant's assumption of debtor's title insurance policy liabilities.

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