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By Ed Boltz, 20 November, 2025

Bankr. M.D.N.C.: In re Lombrano- No Automatic Stay for 3rd Filing

Summary:

In In re Lombrano, Judge Kahn confronted the all-too-common BAPCPA problem of repeat filings colliding head-on with the automatic stay provisions. Ms. Lombrano—pro se—had filed three bankruptcy cases in under five months, two Chapter 7s (one dismissed for filing defects and jurisdictional issues, the next for nonpayment of the fee) followed by this Chapter 13.

By Ed Boltz, 19 November, 2025

Bankr. E.D.N.C.: In re Williams- Yet another Forged Bankruptcy Court Order

Summary:

Judge Warren’s latest sanctions order reads like a greatest-hits compilation of the Eastern District’s prior encounters with bankruptcy document forgery—Wilds, Purdy, and now Williams—but with one glaring distinction: unlike Ms. Sugar, whose saga wound its way to the Fourth Circuit and back on the strength of a plausible (and ultimately successful) reliance on counsel argument, Deja Williams had no attorney to blame but herself.

By Ed Boltz, 17 November, 2025

Law Review (Note): Maxwell Newman, The Advice of Counsel Defense: No Longer a Fraudster’s Shield, 29 N.C. BANKING INST. 558 (2025

Available at:  https://scholarship.law.unc.edu/ncbi/vol29/iss1/19

Abstract/Introduction:

By Ed Boltz, 14 November, 2025

Law Review: Skeel, David A., Debt's Dominion: A New Epilogue (October 21, 2025). U of Penn, Inst for Law & Econ Research Paper No. 25-16, BYU Law Review, forthcoming, 2025

Available at:  https://ssrn.com/abstract=5647631 or http://dx.doi.org/10.2139/ssrn.5647631

By Ed Boltz, 14 November, 2025

[ACBC] Law Review: Pardo, Rafael I., Specialization and the Permanence of Federal Bankruptcy Law (August 08, 2025). Brigham Young University Law Review, Volume 51 (forthcoming 2026)

Available at SSRN: https://ssrn.com/abstract=5641971 or http://dx.doi.org/10.2139/ssrn.5641971

By Ed Boltz, 12 November, 2025

Bankr. M.D.N.C.: In re Peters- No Interest on DMI in Chapter 13

Summary:

In In re Peters, Judge Kahn addressed a  recurring question: when Chapter 13 debtors propose to pay unsecured claims in full under §1325(b)(1)(A), must those creditors also receive post-petition interest?

By Ed Boltz, 4 November, 2025

M.D.N.C.: Brown v. First Advantage Background Services Corp. & Ashcott, LLC II- Minimal Emotional Distress Damages

Summary:

By Ed Boltz, 31 October, 2025

4th Cir.: In re Bestwall LLC (4th Cir. Oct. 30, 2025) — Solvent Debtor Allowed in Texas Two-Step Bankruptcy, En Banc Rehearing Denied over Fiery Dissent

Summary:

The Fourth Circuit, by an 8–6 vote, declined to rehear Bestwall LLC v.

By Ed Boltz, 30 October, 2025

Law Review (Economics): Hollenbeck, Brett and Larsen, Poet and Proserpio, Davide, The Financial Consequences of Legalized Sports Gambling

Available at:   https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4903302

Abstract:

By Ed Boltz, 29 October, 2025

4th Cir.: All American Black Car Service, Inc. v. Gondal — Setoff, Ratification, and the Limits of Lay Testimony in Bankruptcy Litigation

Summary:

In this unpublished October 15, 2025, decision, the Fourth Circuit affirmed the rulings of the Bankruptcy Court and the Eastern District of Virginia in a messy dispute arising from the dissolution of a small limousine company, All American Black Car Service, Inc. (“AABCS”). The case reads like a familiar tale of closely-held corporate dissolution gone awry—complete with COVID-era losses, unwritten understandings, and shareholder distrust—transposed into the bankruptcy context.

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