The United States District Court for the Northern District of Texas recently considered the question of which statute applies when a district court seeks to transfer a case related to a bankruptcy proceeding:  28 U.S.C. § 1404 or 28 U.S.C. § 1412?  The answer to this venue question has split district courts across the country.

On November 2, 2015, Judge Brendan L. Shannon walked a pair of litigants through the factors used in the Third Circuit to determine whether to grant a motion to transfer venue.  In the adversary proceeding Fred C. Caruso v. Fasig-Tipton Co. (In re: Revstone Industries), docketed as Adversary Case No. 14-50468, Judge Shannon issued a