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549

Puerto Rico Bondholders Lose Another Appeal in the First Circuit

The First Circuit shows no inclination to allow creditors to bust out of the PROMESA restructuring of Puerto Rico’s debt.
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Ninth Circuit Creates a Legal Fiction to Uphold Recovery of an Unauthorized Transfer

Ninth Circuit assumed that transferred property must remain property of the estate after conversion from ‘13’ to ‘7’ before the chapter 7 trustee can avoid an unauthorized transfer under Section 549.
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