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Business Restructuring Review Vol. 24, No. 4 | July–August 2025

The Ad Hoc Group of Senior Secured Noteholders and DIP Lenders (the “Ad Hoc Group”) obtained a unanimous judgment in their favor in an appeal following Sanchez Energy Company’s long-running, hard-fought bankruptcy case. Once...more

New York Bankruptcy Court Adopts "Realistic Possibility" Standard for Free and Clear Sales Under 11 U.S.C § 363(f)(5)

Section 363(f)(5) of the Bankruptcy Code allows a bankruptcy trustee to sell estate property free and clear of any competing interest in the property (such as a lien or other security interest) if the interest holder "could...more

Fifth Circuit Suggests Claims for Make-Whole Amounts Should Be Disallowed

The Situation On January 17, 2019, the Fifth Circuit strongly suggested that claims for make-whole damages be characterized as "unmatured interest" and that claims for postpetition interest on unsecured debt be limited in...more

Two Recent Decisions Demonstrate Continued Disagreement Over Whether Economic Value or Face Amount of Liens Is Appropriate Metric...

The ability of a trustee or chapter 11 debtor in possession ("DIP") to sell bankruptcy estate assets "free and clear" of liens on the property under section 363(f) of the Bankruptcy Code has long been recognized as one of the...more

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