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Congress Needs to Fix the Mess Created by the Supreme Court in Lamie

Unlike debtors in chapter 13, chapter 7 debtors cannot pay counsel with estate property. There may be no workaround allowing chapter 7 debtors to pay counsel before filing for services to be performed after filing.

Disgorgement Was the Remedy for Failure to Disclose a Post-Petition Retainer

Disclosing a post-petition retainer in a monthly operating report wasn’t a substitute for disclosure required by Rule 2016(b)(2).
9th Circuit May 7, 2025

How to Liquidate a Secured Lender’s Collateral and Still Get Paid

To liquidate an underwater lender’s collateral, there must be a carveout giving unsecured creditors a ‘meaningful distribution.’