In re O’Gorman (Lovering Tubbs Trust v. Hoffman) (9th Cir. 2024) (A Chapter 7 trustee had standing to sue to recover a fraudulent conveyance under 11 USC 548. The conveyance harmed the bankrupt estate by removing property from the estate. As estate representative, the trustee had standing to redress that harm. The trustee did not need to show that any creditor of the estate was harmed by the conveyance. Injury to a creditor is not an element of an 11 USC 548 claim. The bankruptcy court correctly granted the trustee summary judgment on his fraudulent conveyance claim. The debtor’s declaration admitted intent to hinder or delay a creditor; the conveyance was made to avoid a creditor’s foreclosure sale. It is not necessary to prove fraudulent intent in addition.)