Judge Harner Gives Contours to the Amorphous Notion of ‘New Value’

The ‘new value’ offered by old equity in a chapter 11 plan was insufficient because it was only a small fraction of claims and because the dividend to creditors was also small.

Two Judges Agree: A Class with No Votes Isn’t Considered in Confirming a Sub V Plan

One month apart, two Houston bankruptcy judges held that a non-voting class is not deemed to have voted against a plan.