Baroni v. Seror (In re Baroni), Nos. 21-55076, 21-55150, 2022 U.S. App. LEXIS 15704 (9th Cir. June 8, 2022)
A party moving under 11 USC 1112(b)(1) for relief such as conversion of a Chapter 11 case to a Chapter 7 case bears the burden of persuasion that cause exists for granting that relief. Cause includes a material default in making payments due under the Chapter 11 plan. Material isn't defined by the Bankruptcy Code, but gains meaning from the… Read More