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In re Seidling - Transfer by Affidavit Valid Under Wis. Stat. § 867.03

The United States Bankruptcy Court for the Western District of Wisconsin ruled that a Transfer by Affidavit under Wisconsin Statute § 867.03 is valid when used by a single heir to take legal title to real property valued at $50,000 or less from a decedent's estate, and that the heir can subsequently transfer that property to a third party. The court disallowed Claim No. 13 filed by the Estate of Douglas Thake, which sought $528,970.52 from debtor Bernard Seidling under a civil theft theory, finding that Taylor's transfer to Seidling (via LCO Trust II) was legally effective. The ruling clarifies the scope of Wisconsin's small-estate transfer procedure and its effect on title.

Badalov v. Buzhunashvili — Summary Judgment on Fraud Nondischargeability Claim

Judge Rachel M. Blise granted summary judgment to debtors Emin Buzhunashvili and Irene Gelfand in adversary proceeding No. 24-00054-rmb, dismissing plaintiff Seymour Badalov's claim that approximately $72,269 invested in EMIL Corp. (a restaurant business) was obtained through fraud and should be declared nondischargeable under 11 U.S.C. § 523(a)(2)(A). The court found that none of the alleged statements — including representations about business solvency, growth, and expansion plans — constitute actionable misrepresentations under Wisconsin law, and that Badalov could not establish the required reliance element given his prior knowledge of the business's financial struggles. Summary judgment was granted in full; no trial is required.

Christopher E. Maeder Chapter 13 Bad Faith Conversion Ruling

The US Bankruptcy Court for the Western District of Wisconsin granted motions by Eternix Ltd. and the United States Trustee to convert debtor Christopher E. Maeder's Chapter 13 case to Chapter 7. The Court found that Maeder filed his Chapter 13 petition in bad faith, citing extensive pre-bankruptcy asset shielding, manipulation of schedules, lavish undisclosed spending, and admission that the sole purpose of the bankruptcy was to avoid repaying approximately $110 million in copyright infringement debt owed to Eternix Ltd. Maeder's software company CivilGEO Inc. was also involved in the underlying intellectual property dispute.