In many chapter 11 cases, a committee of unsecured creditors is formed early in the case to represent the overall interests of unsecured creditors. See 11 U.S.C. § 1102. Members of the committee hold a “fiduciary” obligation to the entire general unsecured creditors’ class. Notably, each member of an unsecured creditors committee is

The Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”) govern procedure in cases arising under title 11 of the United States Code. Over time, the Bankruptcy Rules have been amended, and were most recently amended in 2020. The 2020 amendments to the Bankruptcy Rules took effect on December 1, 2020, and govern all proceedings commenced

In July 2020, the Court in In re Generation Res. Holding Co., LLC, 964 F.3d 958, 962 (10th Cir. 2020), held that subsequent transferees do not qualify as immediate or mediate transferees under Section 550(a)(2) because they did not possess the initial property transferred, and only possessed the proceeds of the transfer. In Generation