October 4, 2021
Dear constituency list members of the Insolvency Law Committee
The following is a case update written by Uzzi O. Raanan, a partner at Danning, Gill, Israel & Krasnoff, LLP, analyzing a recent decision of interest:
Deciding a previously unresolved issue, United States Bankruptcy Judge Christopher B. Latham, of the Southern District of California, held that a legal fee award entered in a civil action that is litigated parallel to and intertwined with ongoing dissolution proceedings comes within the scope of a discharge exception under 11 U.S.C. section 523(a)(15), in that it is “in the course of a divorce or separation” or “in connection with [an]… other order of a court of record.” In re Bohrer, 2021 WL 1915991 (Bankr. S.D. Cal. 2021).
Here’s a link to the writeup on the CLA website: click here.
To read the full opinion, click here.