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Judge Kenneth D. Bell’s denial of Navient’s motion for summary judgment in Ready v. Navient (W.D.N.C. No. 5:24-cv-00050) is a sharp reminder that even student loan creditors must prove the underlying debt. Navient insisted that Ms. Christy Ready had taken out a 1995 consolidation loan through “Citibank (NYS)” which was later rolled into a 2002 consolidation. Ms.

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Carolina Sleep Shoppe, LLC filed a Subchapter V Chapter 11 in April 2024. Despite expectations of a consensual plan, no creditor cast a ballot, resulting in a non-consensual cramdown confirmation under § 1191(b). The Debtor proceeded to substantially consummate the plan, pay all administrative expenses, and begin distributions—particularly to its only secured creditor, the SBA.