.jpg)
Impact on family of being forced to move out from home
Thank you!!!
On Wed, Nov 11, 2015 at 10:02 AM, 'Mark J. Markus' bklawr@yahoo.com
[cdcbaa] wrote:
>
>
>
>
> *791 F.3d 1140 (2015) (9th Cir. 2015) *
>
> --
>
> *************************
> Mark J. Markus
> Law Office of Mark J. Markus
> *Mailing Address Only:*
> 11684 Ventura Blvd. PMB #403
> Studio City, CA 91604-2652
> (818)509-1173 (818)332-1180 (fax)
> web: http://www.bklaw.com/
> Certified Bankruptcy Law Specialist--The State Bar of California Board of
> Legal Specialization
> This Firm is a Qualified Federal Debt Relief Agency
> ________________________________________________
> NOTICE: This Electronic Message contains information from the law office
> of Mark J. Markus that may be privileged. The information is intended for
> the use of the addressee only. If you are not the addressee, note that any
> disclosure, copy, distribution or use of the contents of this message is
> prohibited.
> IRS CIRCULAR 230 NOTICE: To ensure compliance with requirements imposed by
> the IRS, we inform you that any U.S. tax advice contained in this
> communication (or in any attachment) is not intended or written to be used,
> and cannot be used, for the purpose of (i) avoiding penalties under the
> Internal Revenue Code or (ii) promoting, marketing or recommending to
> another party any transaction or matter addressed in this communication.
>
> On 11/11/2015 9:51 AM, Giovanni Orantes go@gobklaw.com [cdcbaa] wrote:
>
> What is the official citation for it? I already had it but hoped you had
> the citation. My Westlaw is down.
>
> On Wed, Nov 11, 2015 at 9:50 AM, Giovanni Orantes go@gobklaw.com> wrote:
>
>> Thank you, Mike.
>>
>> On Wed, Nov 11, 2015 at 9:33 AM, Michael Avanesian
>> michael@avanesianlaw.com [cdcbaa] > cdcbaa@yahoogroups.com> wrote:
>>
>>>
>>> Hi Gio,
>>>
>>> I want to make sure you also read the recent 9th Circuit decision on
>>> equitable mootness too. It came out in September so might not be on your
>>> radar.
>>> http://cdn.ca9.uscourts.gov/datastore/o ... -17176.pdf
>>>
>>>
>>> Sincerely,
>>>
>>> *Michael Avanesian, Esq. *
>>> Avanesian Law Firm
>>> 101 N. Brand Blvd. PH 1920
>>> Glendale, CA 91203
>>> Tel: 818.276.2477 | Fax: 818.208.4550
>>>
>>> *Confidentiality**: *This electronic transmission and its contents are
>>> legally privileged and confidential information and intended solely for the
>>> use of the addressee. If the reader of this message is not the intended
>>> recipient, you are hereby notified that any dissemination, distribution,
>>> copying or other use of this message and its contents is strictly
>>> prohibited. If you have received this transmission in error, please reply
>>> to us immediately and delete this message from your directory.
>>>
>>> *IRS Circular 230 Disclosure:* To ensure compliance with requirements
>>> imposed by the IRS, please be advised that any U.S. federal tax advice
>>> contained in this communication (including any attachments) is not intended
>>> or written to be used or relied upon, and cannot be used or relied upon,
>>> for the purpose of (i) avoiding penalties under the Internal Revenue Code,
>>> or (ii) promoting, marketing or recommending to another party any
>>> transaction or matter addressed herein.
>>>
>>> On Wed, Nov 11, 2015 at 6:57 AM, Giovanni Orantes go@gobklaw.com
>>> [cdcbaa] wrote:
>>>
>>>>
>>>> I have to argue that not staying execution of a relief from stay order
>>>> while we appeal and instead allowing the post-petition purchaser of a
>>>> property to evict my client and her family would render an appeal equitably
>>>> moot under the Clear Channel v. Knupfer case
>>>> *(i.e., In re PW, LLC, ( Clear Channel Outdoor, Inc. v. Nancy
>>>> Knupfer). I am aware that I can and already filed a complaint to avoid
>>>> the sale if the purchase price was for less than fair equivalent value, but
>>>> the Judge has asked me to brief equitable mootness by noon today.*
>>>>
>>>> The family's four minor children attend local schools in a renowned
>>>> school district. My client is now about 30 and attended that school
>>>> district since about age 9 and she raises the 4 children. (1) I'm sure it
>>>> would be traumatic to be evicted from their house; embarrassing (any
>>>> studies about that somewhere?); (2) they would have to move into another
>>>> residence nearby (3) if that is even possible as there aren't many
>>>> properties available for rent nearby and my clients will be appealing any
>>>> threat to take the house to the Supreme Court, if necessary; (4) they would
>>>> have to make new friends, which is easier for some people more than for
>>>> others and at least one of the household members has social skills issues. *Any
>>>> other issues you all can think of? Don't worry if you repeat any issues
>>>> already listed by me or others.*
>>>>
>>>>
>>>>
>>>> --
>>>> Giovanni Orantes, Esq.*
>>>> Orantes Law Firm, P.C.
>>>> 3435 Wilshire Blvd. Suite 2920
>>>> Los Angeles, CA 90010
>>>> Tel: (213) 389-4362
>>>> Fax: (877) 789-5776
>>>> e-mail: go@gobklaw.com
>>>> website: www.gobklaw.com
>>>>
>>>> **Certified Bankruptcy Specialist, State Bar of California, Board of
>>>> Legal Specialization*
>>>> *Board Certified - Business Bankruptcy Law - American Board of
>>>> Certification
>>>> *Board Certified - Consumer Bankruptcy Law - American Board of
>>>> Certification
>>>> Commercial Litigation
>>>> Estate Planning
>>>> Outside General Counsel
>>>>
>>>>
>>>>
>>>> WE ARE A "DEBT RELIEF AGENCY" AS DEFINED BY FEDERAL LAW.
>>>>
>>>> SERVING BAKERSFIELD, LOS ANGELES, ORANGE COUNTY, RIVERSIDE, SAN
>>>> BERNARDINO AND SANTA BARBARA AND THE WORLD FOR CHAPTER 11 AND 15 CASES.
>>>>
>>>> Note: The information in this e-mail message is not intended to be
>>>> legal advice and should not be relied upon as legal advice unless counsel
>>>> expressly contracted in writing to provide such advice. Furthermore, the
>>>> information contained in this e-mail message is confidential information
>>>> intended only for the use of the individual or entity named. If the reader
>>>> of this message is not the intended recipient or an agent responsible for
>>>> delivering it to the intended recipient, you are hereby notified that any
>>>> dissemination, distribution or copy of this communication is strictly
>>>> prohibited. If you have received this communication in error, please
>>>> immediately notify us by telephone or e-mail and delete the original e-mail
>>>> at (213) 389-4362 or (888) 619-8222.
>>>>
>>>
>>>
>>
>>
>> --
>> Giovanni Orantes, Esq.*
>> Orantes Law Firm, P.C.
>> 3435 Wilshire Blvd. Suite 2920
>> Los Angeles, CA 90010
>> Tel: (213) 389-4362
>> Fax: (877) 789-5776
>> e-mail: go@gobklaw.com
>> website: www.gobklaw.com
>>
>> **Certified Bankruptcy Specialist, State Bar of California, Board of
>> Legal Specialization*
>> *Board Certified - Business Bankruptcy Law - American Board of
>> Certification
>> *Board Certified - Consumer Bankruptcy Law - American Board of
>> Certification
>> Commercial Litigation
>> Estate Planning
>> Outside General Counsel
>>
>>
>>
>> WE ARE A "DEBT RELIEF AGENCY" AS DEFINED BY FEDERAL LAW.
>>
>> SERVING BAKERSFIELD, LOS ANGELES, ORANGE COUNTY, RIVERSIDE, SAN
>> BERNARDINO AND SANTA BARBARA AND THE WORLD FOR CHAPTER 11 AND 15 CASES.
>>
>> Note: The information in this e-mail message is not intended to be legal
>> advice and should not be relied upon as legal advice unless counsel
>> expressly contracted in writing to provide such advice. Furthermore, the
>> information contained in this e-mail message is confidential information
>> intended only for the use of the individual or entity named. If the reader
>> of this message is not the intended recipient or an agent responsible for
>> delivering it to the intended recipient, you are hereby notified that any
>> dissemination, distribution or copy of this communication is strictly
>> prohibited. If you have received this communication in error, please
>> immediately notify us by telephone or e-mail and delete the original e-mail
>> at (213) 389-4362 or (888) 619-8222
>> .
>>
>
>
>
> --
> Giovanni Orantes, Esq.*
> Orantes Law Firm, P.C.
> 3435 Wilshire Blvd. Suite 2920
> Los Angeles, CA 90010
> Tel: (213) 389-4362
> Fax: (877) 789-5776
> e-mail: go@gobklaw.com
> website: www.gobklaw.com
>
> **Certified Bankruptcy Specialist, State Bar of California, Board of Legal
> Specialization*
> *Board Certified - Business Bankruptcy Law - American Board of
> Certification
> *Board Certified - Consumer Bankruptcy Law - American Board of
> Certification
> Commercial Litigation
> Estate Planning
> Outside General Counsel
>
>
>
> WE ARE A "DEBT RELIEF AGENCY" AS DEFINED BY FEDERAL LAW.
>
> SERVING BAKERSFIELD, LOS ANGELES, ORANGE COUNTY, RIVERSIDE, SAN BERNARDINO
> AND SANTA BARBARA AND THE WORLD FOR CHAPTER 11 AND 15 CASES.
>
> Note: The information in this e-mail message is not intended to be legal
> advice and should not be relied upon as legal advice unless counsel
> expressly contracted in writing to provide such advice. Furthermore, the
> information contained in this e-mail message is confidential information
> intended only for the use of the individual or entity named. If the reader
> of this message is not the intended recipient or an agent responsible for
> delivering it to the intended recipient, you are hereby notified that any
> dissemination, distribution or copy of this communication is strictly
> prohibited. If you have received this communication in error, please
> immediately notify us by telephone or e-mail and delete the original e-mail
> at (213) 389-4362 or (888) 619-8222.
>
>
>
>
>
Giovanni Orantes, Esq.*
Orantes Law Firm, P.C.
3435 Wilshire Blvd. Suite 2920
Los Angeles, CA 90010
Tel: (213) 389-4362
Fax: (877) 789-5776
e-mail: go@gobklaw.com
website: www.gobklaw.com
**Certified Bankruptcy Specialist, State Bar of California, Board of Legal
Specialization*
*Board Certified - Business Bankruptcy Law - American Board of Certification
*Board Certified - Consumer Bankruptcy Law - American Board of Certification
Commercial Litigation
Estate Planning
Outside General Counsel
WE ARE A "DEBT RELIEF AGENCY" AS DEFINED BY FEDERAL LAW.
SERVING BAKERSFIELD, LOS ANGELES, ORANGE COUNTY, RIVERSIDE, SAN BERNARDINO
AND SANTA BARBARA AND THE WORLD FOR CHAPTER 11 AND 15 CASES.
Thank you!!!
The post was migrated from Yahoo.
What is the official citation for it? I already had it but hoped you had
the citation. My Westlaw is down.
On Wed, Nov 11, 2015 at 9:50 AM, Giovanni Orantes wrote:
> Thank you, Mike.
>
> On Wed, Nov 11, 2015 at 9:33 AM, Michael Avanesian
> michael@avanesianlaw.com [cdcbaa] wrote:
>
>>
>>
>> Hi Gio,
>>
>> I want to make sure you also read the recent 9th Circuit decision on
>> equitable mootness too. It came out in September so might not be on your
>> radar.
>> http://cdn.ca9.uscourts.gov/datastore/o ... -17176.pdf
>>
>>
>> Sincerely,
>>
>> *Michael Avanesian, Esq. *
>> Avanesian Law Firm
>> 101 N. Brand Blvd. PH 1920
>> Glendale, CA 91203
>> Tel: 818.276.2477 | Fax: 818.208.4550
>>
>> *Confidentiality**: *This electronic transmission and its contents are
>> legally privileged and confidential information and intended solely for the
>> use of the addressee. If the reader of this message is not the intended
>> recipient, you are hereby notified that any dissemination, distribution,
>> copying or other use of this message and its contents is strictly
>> prohibited. If you have received this transmission in error, please reply
>> to us immediately and delete this message from your directory.
>>
>> *IRS Circular 230 Disclosure:* To ensure compliance with requirements
>> imposed by the IRS, please be advised that any U.S. federal tax advice
>> contained in this communication (including any attachments) is not intended
>> or written to be used or relied upon, and cannot be used or relied upon,
>> for the purpose of (i) avoiding penalties under the Internal Revenue Code,
>> or (ii) promoting, marketing or recommending to another party any
>> transaction or matter addressed herein.
>>
>>
>> On Wed, Nov 11, 2015 at 6:57 AM, Giovanni Orantes go@gobklaw.com
>> [cdcbaa] wrote:
>>
>>>
>>>
>>> I have to argue that not staying execution of a relief from stay order
>>> while we appeal and instead allowing the post-petition purchaser of a
>>> property to evict my client and her family would render an appeal equitably
>>> moot under the Clear Channel v. Knupfer case
>>> *(i.e., In re PW, LLC, (Clear Channel Outdoor, Inc. v. Nancy Knupfer).
>>> I am aware that I can and already filed a complaint to avoid the sale if
>>> the purchase price was for less than fair equivalent value, but the Judge
>>> has asked me to brief equitable mootness by noon today.*
>>>
>>> The family's four minor children attend local schools in a renowned
>>> school district. My client is now about 30 and attended that school
>>> district since about age 9 and she raises the 4 children. (1) I'm sure it
>>> would be traumatic to be evicted from their house; embarrassing (any
>>> studies about that somewhere?); (2) they would have to move into another
>>> residence nearby (3) if that is even possible as there aren't many
>>> properties available for rent nearby and my clients will be appealing any
>>> threat to take the house to the Supreme Court, if necessary; (4) they would
>>> have to make new friends, which is easier for some people more than for
>>> others and at least one of the household members has social skills issues. *Any
>>> other issues you all can think of? Don't worry if you repeat any issues
>>> already listed by me or others.*
>>>
>>>
>>>
>>> --
>>> Giovanni Orantes, Esq.*
>>> Orantes Law Firm, P.C.
>>> 3435 Wilshire Blvd. Suite 2920
>>> Los Angeles, CA 90010
>>> Tel: (213) 389-4362
>>> Fax: (877) 789-5776
>>> e-mail: go@gobklaw.com
>>> website: www.gobklaw.com
>>>
>>> **Certified Bankruptcy Specialist, State Bar of California, Board of
>>> Legal Specialization*
>>> *Board Certified - Business Bankruptcy Law - American Board of
>>> Certification
>>> *Board Certified - Consumer Bankruptcy Law - American Board of
>>> Certification
>>> Commercial Litigation
>>> Estate Planning
>>> Outside General Counsel
>>>
>>>
>>>
>>> WE ARE A "DEBT RELIEF AGENCY" AS DEFINED BY FEDERAL LAW.
>>>
>>> SERVING BAKERSFIELD, LOS ANGELES, ORANGE COUNTY, RIVERSIDE, SAN
>>> BERNARDINO AND SANTA BARBARA AND THE WORLD FOR CHAPTER 11 AND 15 CASES.
>>>
>>> Note: The information in this e-mail message is not intended to be legal
>>> advice and should not be relied upon as legal advice unless counsel
>>> expressly contracted in writing to provide such advice. Furthermore, the
>>> information contained in this e-mail message is confidential information
>>> intended only for the use of the individual or entity named. If the reader
>>> of this message is not the intended recipient or an agent responsible for
>>> delivering it to the intended recipient, you are hereby notified that any
>>> dissemination, distribution or copy of this communication is strictly
>>> prohibited. If you have received this communication in error, please
>>> immediately notify us by telephone or e-mail and delete the original e-mail
>>> at (213) 389-4362 or (888) 619-8222.
>>>
>>>
>>
>>
>
>
>
> --
> Giovanni Orantes, Esq.*
> Orantes Law Firm, P.C.
> 3435 Wilshire Blvd. Suite 2920
> Los Angeles, CA 90010
> Tel: (213) 389-4362
> Fax: (877) 789-5776
> e-mail: go@gobklaw.com
> website: www.gobklaw.com
>
> **Certified Bankruptcy Specialist, State Bar of California, Board of Legal
> Specialization*
> *Board Certified - Business Bankruptcy Law - American Board of
> Certification
> *Board Certified - Consumer Bankruptcy Law - American Board of
> Certification
> Commercial Litigation
> Estate Planning
> Outside General Counsel
>
>
>
> WE ARE A "DEBT RELIEF AGENCY" AS DEFINED BY FEDERAL LAW.
>
> SERVING BAKERSFIELD, LOS ANGELES, ORANGE COUNTY, RIVERSIDE, SAN BERNARDINO
> AND SANTA BARBARA AND THE WORLD FOR CHAPTER 11 AND 15 CASES.
>
> Note: The information in this e-mail message is not intended to be legal
> advice and should not be relied upon as legal advice unless counsel
> expressly contracted in writing to provide such advice. Furthermore, the
> information contained in this e-mail message is confidential information
> intended only for the use of the individual or entity named. If the reader
> of this message is not the intended recipient or an agent responsible for
> delivering it to the intended recipient, you are hereby notified that any
> dissemination, distribution or copy of this communication is strictly
> prohibited. If you have received this communication in error, please
> immediately notify us by telephone or e-mail and delete the original e-mail
> at (213) 389-4362 or (888) 619-8222.
>
Giovanni Orantes, Esq.*
Orantes Law Firm, P.C.
3435 Wilshire Blvd. Suite 2920
Los Angeles, CA 90010
Tel: (213) 389-4362
Fax: (877) 789-5776
e-mail: go@gobklaw.com
website: www.gobklaw.com
**Certified Bankruptcy Specialist, State Bar of California, Board of Legal
Specialization*
*Board Certified - Business Bankruptcy Law - American Board of Certification
*Board Certified - Consumer Bankruptcy Law - American Board of Certification
Commercial Litigation
Estate Planning
Outside General Counsel
WE ARE A "DEBT RELIEF AGENCY" AS DEFINED BY FEDERAL LAW.
SERVING BAKERSFIELD, LOS ANGELES, ORANGE COUNTY, RIVERSIDE, SAN BERNARDINO
AND SANTA BARBARA AND THE WORLD FOR CHAPTER 11 AND 15 CASES.
Note: The information in this e-mail message is not intended to be legal
advice and should not be relied upon as legal advice unless counsel
expressly contracted in writing to provide such advice. Furthermore, the
information contained in this e-mail message is confidential information
intended only for the use of the individual or entity named. If the reader
of this message is not the intended recipient or an agent responsible for
delivering it to the intended recipient, you are hereby notified that any
dissemination, distribution or copy of this communication is strictly
prohibited. If you have received this communication in error, please
immediately notify us by telephone or e-mail and delete the original e-mail
What is the official citation for it? I already had it but hoped you had the citation. My Westlaw is down.On Wed, Nov 11, 2015 at 9:50 AM, Giovanni Orantes <go@gobklaw.com> wrote:Thank you, Mike.On Wed, Nov 11, 2015 at 9:33 AM, Michael Avanesian michael@avanesianlaw.com [cdcbaa] <cdcbaa@yahoogroups.com> wrote:
Hi Gio,I want to make sure you also read the recent 9th Circuit decision on equitable mootness too. It came out in September so might not be on your radar.Giovanni Orantes, Esq.*Orantes Law Firm, P.C.3435 Wilshire Blvd. Suite 2920Los Angeles, CA 90010Tel: (213) 389-4362Fax: (877) 789-5776e-mail: go@gobklaw.comwebsite: www.gobklaw.com
The post was migrated from Yahoo.
Thank you, Mike.
On Wed, Nov 11, 2015 at 9:33 AM, Michael Avanesian michael@avanesianlaw.com
[cdcbaa] wrote:
>
>
> Hi Gio,
>
> I want to make sure you also read the recent 9th Circuit decision on
> equitable mootness too. It came out in September so might not be on your
> radar.
> http://cdn.ca9.uscourts.gov/datastore/o ... -17176.pdf
>
>
> Sincerely,
>
> *Michael Avanesian, Esq. *
> Avanesian Law Firm
> 101 N. Brand Blvd. PH 1920
> Glendale, CA 91203
> Tel: 818.276.2477 | Fax: 818.208.4550
>
> *Confidentiality**: *This electronic transmission and its contents are
> legally privileged and confidential information and intended solely for the
> use of the addressee. If the reader of this message is not the intended
> recipient, you are hereby notified that any dissemination, distribution,
> copying or other use of this message and its contents is strictly
> prohibited. If you have received this transmission in error, please reply
> to us immediately and delete this message from your directory.
>
> *IRS Circular 230 Disclosure:* To ensure compliance with requirements
> imposed by the IRS, please be advised that any U.S. federal tax advice
> contained in this communication (including any attachments) is not intended
> or written to be used or relied upon, and cannot be used or relied upon,
> for the purpose of (i) avoiding penalties under the Internal Revenue Code,
> or (ii) promoting, marketing or recommending to another party any
> transaction or matter addressed herein.
>
>
> On Wed, Nov 11, 2015 at 6:57 AM, Giovanni Orantes go@gobklaw.com [cdcbaa]
> wrote:
>
>>
>>
>> I have to argue that not staying execution of a relief from stay order
>> while we appeal and instead allowing the post-petition purchaser of a
>> property to evict my client and her family would render an appeal equitably
>> moot under the Clear Channel v. Knupfer case
>> *(i.e., In re PW, LLC, (Clear Channel Outdoor, Inc. v. Nancy Knupfer). I
>> am aware that I can and already filed a complaint to avoid the sale if the
>> purchase price was for less than fair equivalent value, but the Judge has
>> asked me to brief equitable mootness by noon today.*
>>
>> The family's four minor children attend local schools in a renowned
>> school district. My client is now about 30 and attended that school
>> district since about age 9 and she raises the 4 children. (1) I'm sure it
>> would be traumatic to be evicted from their house; embarrassing (any
>> studies about that somewhere?); (2) they would have to move into another
>> residence nearby (3) if that is even possible as there aren't many
>> properties available for rent nearby and my clients will be appealing any
>> threat to take the house to the Supreme Court, if necessary; (4) they would
>> have to make new friends, which is easier for some people more than for
>> others and at least one of the household members has social skills issues. *Any
>> other issues you all can think of? Don't worry if you repeat any issues
>> already listed by me or others.*
>>
>>
>>
>> --
>> Giovanni Orantes, Esq.*
>> Orantes Law Firm, P.C.
>> 3435 Wilshire Blvd. Suite 2920
>> Los Angeles, CA 90010
>> Tel: (213) 389-4362
>> Fax: (877) 789-5776
>> e-mail: go@gobklaw.com
>> website: www.gobklaw.com
>>
>> **Certified Bankruptcy Specialist, State Bar of California, Board of
>> Legal Specialization*
>> *Board Certified - Business Bankruptcy Law - American Board of
>> Certification
>> *Board Certified - Consumer Bankruptcy Law - American Board of
>> Certification
>> Commercial Litigation
>> Estate Planning
>> Outside General Counsel
>>
>>
>>
>> WE ARE A "DEBT RELIEF AGENCY" AS DEFINED BY FEDERAL LAW.
>>
>> SERVING BAKERSFIELD, LOS ANGELES, ORANGE COUNTY, RIVERSIDE, SAN
>> BERNARDINO AND SANTA BARBARA AND THE WORLD FOR CHAPTER 11 AND 15 CASES.
>>
>> Note: The information in this e-mail message is not intended to be legal
>> advice and should not be relied upon as legal advice unless counsel
>> expressly contracted in writing to provide such advice. Furthermore, the
>> information contained in this e-mail message is confidential information
>> intended only for the use of the individual or entity named. If the reader
>> of this message is not the intended recipient or an agent responsible for
>> delivering it to the intended recipient, you are hereby notified that any
>> dissemination, distribution or copy of this communication is strictly
>> prohibited. If you have received this communication in error, please
>> immediately notify us by telephone or e-mail and delete the original e-mail
>> at (213) 389-4362 or (888) 619-8222.
>>
>>
>
>
Giovanni Orantes, Esq.*
Orantes Law Firm, P.C.
3435 Wilshire Blvd. Suite 2920
Los Angeles, CA 90010
Tel: (213) 389-4362
Fax: (877) 789-5776
e-mail: go@gobklaw.com
website: www.gobklaw.com
**Certified Bankruptcy Specialist, State Bar of California, Board of Legal
Specialization*
*Board Certified - Business Bankruptcy Law - American Board of Certification
*Board Certified - Consumer Bankruptcy Law - American Board of Certification
Commercial Litigation
Estate Planning
Outside General Counsel
WE ARE A "DEBT RELIEF AGENCY" AS DEFINED BY FEDERAL LAW.
SERVING BAKERSFIELD, LOS ANGELES, ORANGE COUNTY, RIVERSIDE, SAN BERNARDINO
AND SANTA BARBARA AND THE WORLD FOR CHAPTER 11 AND 15 CASES.
Note: The information in this e-mail message is not intended to be legal
advice and should not be relied upon as legal advice unless counsel
expressly contracted in writing to provide such advice. Furthermore, the
information contained in this e-mail message is confidential information
intended only for the use of the individual or entity named. If the reader
of this message is not the intended recipient or an agent responsible for
delivering it to the intended recipient, you are hereby notified that any
dissemination, distribution or copy of this communication is strictly
prohibited. If you have received this communication in error, please
immediately notify us by telephone or e-mail and delete the original e-mail
Thank you, Mike.On Wed, Nov 11, 2015 at 9:33 AM, Michael Avanesian michael@avanesianlaw.com [cdcbaa] <
Hi Gio,I want to make sure you also read the recent 9th Circuit decision on equitable mootness too. It came out in September so might not be on your radar.Giovanni Orantes, Esq.*Orantes Law Firm, P.C.3435 Wilshire Blvd. Suite 2920Los Angeles, CA 90010Tel: (213) 389-4362Fax: (877) 789-5776e-mail: go@gobklaw.comwebsite: www.gobklaw.com
The post was migrated from Yahoo.
I have to argue that not staying execution of a relief from stay order
while we appeal and instead allowing the post-petition purchaser of a
property to evict my client and her family would render an appeal equitably
moot under the Clear Channel v. Knupfer case
*(i.e., In re PW, LLC, (Clear Channel Outdoor, Inc. v. Nancy Knupfer). I
am aware that I can and already filed a complaint to avoid the sale if the
purchase price was for less than fair equivalent value, but the Judge has
asked me to brief equitable mootness by noon today.*
The family's four minor children attend local schools in a renowned school
district. My client is now about 30 and attended that school district
since about age 9 and she raises the 4 children. (1) I'm sure it would be
traumatic to be evicted from their house; embarrassing (any studies about
that somewhere?); (2) they would have to move into another residence nearby
(3) if that is even possible as there aren't many properties available for
rent nearby and my clients will be appealing any threat to take the house
to the Supreme Court, if necessary; (4) they would have to make new
friends, which is easier for some people more than for others and at least
one of the household members has social skills issues. *Any other issues
you all can think of? Don't worry if you repeat any issues already listed
by me or others.*
Giovanni Orantes, Esq.*
Orantes Law Firm, P.C.
3435 Wilshire Blvd. Suite 2920
Los Angeles, CA 90010
Tel: (213) 389-4362
Fax: (877) 789-5776
e-mail: go@gobklaw.com
website: www.gobklaw.com
**Certified Bankruptcy Specialist, State Bar of California, Board of Legal
Specialization*
*Board Certified - Business Bankruptcy Law - American Board of Certification
*Board Certified - Consumer Bankruptcy Law - American Board of Certification
Commercial Litigation
Estate Planning
Outside General Counsel
WE ARE A "DEBT RELIEF AGENCY" AS DEFINED BY FEDERAL LAW.
SERVING BAKERSFIELD, LOS ANGELES, ORANGE COUNTY, RIVERSIDE, SAN BERNARDINO
AND SANTA BARBARA AND THE WORLD FOR CHAPTER 11 AND 15 CASES.
Note: The information in this e-mail message is not intended to be legal
advice and should not be relied upon as legal advice unless counsel
expressly contracted in writing to provide such advice. Furthermore, the
information contained in this e-mail message is confidential information
intended only for the use of the individual or entity named. If the reader
of this message is not the intended recipient or an agent responsible for
delivering it to the intended recipient, you are hereby notified that any
dissemination, distribution or copy of this communication is strictly
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I have to argue that not staying execution of a relief from stay order while we appeal and instead allowing thepost-petitionnappeal equitably moot under the Clear Channel v. Knupfer case (i.e.,In re PW, LLC, (
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