Elizabeth D. Katz

How Judge Katz rules, drawn from 10 signed orders. Every observation links to the order it came from.

Court
U.S. Bankruptcy Court for the District of Massachusetts
Position
bankruptcy
Commissioned
2017-03-13
Signed orders read
10

How Judge Katz decides

Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.

What persuades

A proposed Chapter 13 cure through loan modification is not categorically barred, but an objecting party can still raise case-specific feasibility and good-faith evidence.

“the Court is not persuaded that a Chapter 13 plan cannot be confirmed over a creditor's objection solely on the grounds that a loan modification cannot constitute ‘cure’ under § 1322(b)(5).”

Massachusetts homestead protection can extend to a qualifying principal residence that is also used for business activity.

“the Homestead Exemption is intended to apply to residential properties that may also be used for business purposes or in connection with commercial activities so long as the other conditions of the Homestead Statute are satisfied.”

Documents executed as parts of one integrated loan transaction may be read together to resolve ambiguity in a single instrument.

“any potential ambiguity must be resolved by reference to the loan documents as a whole.”

Accessible home equity may defeat an undue-hardship showing when liquidation can satisfy student loans without preventing a minimal standard of living.

“the existence of equity that could be liquidated to satisfy the debts negates any claim that payment of the loans imposes an undue hardship.”

Procedural preferences

A Chapter 13 debtor generally cannot exercise trustee avoidance powers beyond the narrow authority Congress expressly supplied.

“Chapter 13 debtors do not have standing to exercise a trustee's avoidance powers outside the narrow confines of § 522(h).”

Cautions

A sanctions request must comply with the separate-motion and safe-harbor requirements rather than ask the court to bypass them sua sponte.

“Having failed to comply, the Defendants seek an end run around these procedural requirements by inviting the Court to exercise its sua sponte powers under Rule 9011(c)(1)(B), an invitation which this Court declines.”

Signed rulings

A grounded sample of orders signed by this judge, with the verbatim dispositive language.

Andrade v. Essenfeld (In re Andrade)
· 2017-07-12
Sua sponte dismissal of section 363h claim (Court) Granted

“Accordingly, the Court will sua sponte DISMISS Count I of the Debtor’s complaint.”

In re Unacha; In re Flynn; In re Benoit
18-40036; 18-41098; 18-41136 · 2019-04-23
Objection to chapter 13 plan confirmation (The Bank of New York Mellon) Granted in part

“each of the Objections to the Debtors' Plans will be overruled in part and sustained in part”

Objection to chapter 13 plan confirmation (Federal National Mortgage Association) Granted in part
Objection to chapter 13 plan confirmation (U.S. Bank National Association) Granted in part
Fortin v. Federal National Mortgage Association and Nationstar Mortgage, LLC (In re Fortin)
· 2019-03-05
Motion for partial judgment on the pleadings (Federal National Mortgage Association and Nationstar Mortgage, LLC) Granted

“Accordingly, the Defendants' request for judgment as to Count II will be granted.”

Request for order to show cause re sanctions (Federal National Mortgage Association and Nationstar Mortgage, LLC) Denied

“As for the Defendants' urging this Court to issue an order to show cause why the Debtor should not be sanctioned for refusing to voluntarily dismiss Count II with prejudice, that request must be denied.”

In re Sjogren
· 2017-07-12
Objection to chapter 13 plan confirmation (Chapter 13 trustee) Granted

“the Court will SUSTAIN the Trustee’s objection”

In re Shove
· 2018-05-29
Motion to avoid judicial lien (Richard M. Shove and Kathleen E. Shove) Granted

“the Court will GRANT the Debtors' Motion.”

White v. Gaffney (In re Lloyd)
· 2019-06-28
Sua sponte dismissal of breach of contract claim (Court) Granted

“the Court has no jurisdiction to adjudicate them, and the complaint must therefore be DISMISSED.”

Sua sponte dismissal of malpractice claim (Court) Granted
Sua sponte dismissal of breach of fiduciary duty claim (Court) Granted
Sua sponte dismissal of unjust enrichment claim (Court) Granted
Sua sponte dismissal of implied covenant claim (Court) Granted
Sua sponte dismissal of accounting claim (Court) Granted
Sua sponte dismissal of chapter 93a claim (Court) Granted
D'Alessio v. CIT Bank, N.A. (In re D'Alessio)
· 2018-06-11
Objection to chapter 13 plan confirmation (CIT Bank, N.A.) Granted

“the Plan Objection will be sustained”

Motion for relief from stay (CIT Bank, N.A.) Granted

“the Motion for Relief from Stay will be granted”

Summary judgment (CIT Bank, N.A.) Granted

“the Summary Judgment Motion will be granted”

Schatz v. U.S. Department of Education, Access Group, Inc., and Massachusetts Educational Financing Authority (In re Schatz)
· 2018-05-02
Request to discharge student loans for undue hardship (Audrey Eve Schatz) Denied

“Accordingly, a judgment in favor of the Defendants and in conformity with this Memorandum shall enter forthwith.”

Goldsmith v. Macri Associates, Inc. (In re E & G Waterworks, LLC)
· 2017-07-27
Motion to compel arbitration (Macri Associates, Inc.) Denied

“The Arbitration Motion will therefore be denied as to Count I.”

Kalesnik v. HSBC Bank USA, National Association and Ocwen Loan Servicing, LLC (In re Kalesnik)
15-30597; 16-3027 · 2017-07-11
Motion to dismiss section 544 avoidance claim (HSBC Bank USA, National Association and Ocwen Loan Servicing, LLC) Granted

“Counts I-IV and VI-VII will all be dismissed.”

Motion to dismiss breach of contract claim (HSBC Bank USA, National Association and Ocwen Loan Servicing, LLC) Granted
Motion to dismiss wrongful eviction conversion claim (HSBC Bank USA, National Association and Ocwen Loan Servicing, LLC) Granted
Motion to dismiss breach of quiet enjoyment claim (HSBC Bank USA, National Association and Ocwen Loan Servicing, LLC) Granted
Motion to dismiss chapter 93a claim (HSBC Bank USA, National Association and Ocwen Loan Servicing, LLC) Denied

“as to that claim (Count V) the Motion to Dismiss will be denied.”

Motion to dismiss misrepresentation claim (HSBC Bank USA, National Association and Ocwen Loan Servicing, LLC) Granted
Motion to dismiss intentional infliction of emotional distress claim (HSBC Bank USA, National Association and Ocwen Loan Servicing, LLC) Granted

Draft for Judge Katz with the record in hand

Ezel grounds your drafting and research in this profile: what has persuaded Judge Katz, and what has not, cited to the signed orders.

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