And the hits just keep on coming ...

9th Circuit In re Lehtinen Bankruptcy Attorney/Realtor sanctioned for soliciting Client to list Client's house without disclosing conflict. ________________________ 10th Circuit In re Commercial Financial Services, Inc. Bankruptcy Court did not err in denying $1,000,000 of an investment banker's $1.9 Million Fee Application -- Court properly demanded that the investment banker provide hourly bills rather than flat monthly bills and justify its compensation on that hourly basis. In re Joelson Under 523(a)(2) an oral statement regarding the debtor's financial condition cannot form the basis for a finding of nondischargeability, but a written statement can. For purposes of applying 523(a)(2) a "statement regarding [the debtor's] financial condition" is interpreted strictly to mean one concerning the debtor's overall net worth rather than those pertaining to individual assets. ________________________ In re Kaplan (Bankr. S.D. Fla. 2005) "One conclusion is inescapable. The new law is not a model of clarity." The reform legislation's new $125,000 limit on homesteads applies in all States, not just those that have not opted out. _____________________ In re MDIP, Inc. (Bankr. DE 2005) In the context of motion for summary judgment on the issue of reasonably equivalent value in a constructive fraud case, the Court could not grant summary judgment where a pre-transaction internal report valued the asset transferred to the debtor at less than half of what the debtor paid.