Brian K. Tester

How Judge Tester rules, drawn from 19 signed orders. Every observation links to the order it came from.

Judge Tester no longer hears cases. This profile is preserved as a historical record of how they ruled.

Court
U.S. Bankruptcy Court for the District of Puerto Rico
Position
bankruptcy
Status
No longer serving
Commissioned
2006-11-01
Signed orders read
19

How Judge Tester decides

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

What persuades

Summary judgment requires evidence establishing every material element rather than an incomplete record.

“because of this evidentiary insufficiency, the court is unable to dispose of the controversy at hand via summary judgment”

A negotiated Chapter 12 payment structure may be approved when it reduces reorganization costs without impairing the trustee's duties.

“Direct payments allow Debtor to have a less expensive chapter 12 bankruptcy”

Procedural preferences

Small-business debtors must meet the statutory plan deadline or obtain an extension before it expires.

“the only way to file a plan outside of the 300-day ‘drop dead’ period is to comply with the following requirements”

Cautions

Equitable tolling depends on diligence in examining available filings and following disclosed leads.

“if the court finds that the trustee has not acted diligently, the limitation period will not be equitably tolled.”

Signed rulings

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

Oliveras v. Banco Popular de P.R. (In re Casanova)
· 2018-12-18
Motion to dismiss adversary proceeding (Banco Popular de Puerto Rico) Granted

“the Motion to Dismiss [Dkt. No. 15] filed by Defendant Banco Popular de Puerto Rico is GRANTED. The adversary proceeding is dismissed.”

Benavides Posada v. Banco Popular de Puerto Rico (In re Benavides Posada)
· 2017-07-27
Summary judgment (The debtors and plaintiffs) Denied

“Debtors’/Plaintiffs’ Motion for Summary Judgment [Dkt. No.7] and BPPR’s' Opposition to Plaintiffs Motion for Summary Judgment (Docket No. 7) and Cross Motion for Summary Judgment [Dkt. No. 15] are hereby DENIED.”

Summary judgment (Banco Popular de Puerto Rico) Denied
Santiago v. Scotiabank De Puerto Rico (In re Santiago)
· 2017-06-27
Summary judgment (Motorambar, Inc.) Granted

“Co-Defendant Motorambar, Incorporated’s Summary Judgment Motion [Dkt. No. 66] is GRANTED.”

Request for summary judgment (Scotiabank de Puerto Rico) Granted

“GRANTS Scotiabank summary judgment on all allegations in the Complaint and the Amended Complaint.”

In re Farmacias Puerto Rico
· 2016-08-16
Motion for immediate surrender of premises (SF III PR, LLC) Granted

“the court GRANTS SF’s Urgent Motion for Immediate Surrender of Farmacias Puerto Rico’s Premises [Dkt. No. 25]”

In re Hernandez
· 2016-02-23
Joint stipulation for direct payment (The debtor and Banco Popular de Puerto Rico) Granted

“As such, the Joint Stipulation [Dkt. No. 55] is approved.”

Objection to joint stipulation (The Chapter 12 trustee) Denied
Hernández Díaz v. Asociación de Empleados del Estado Libre Asociado de Puerto Rico (In re Hernández Díaz)
· 2016-01-11
Request to determine property value (The debtors and plaintiffs) Granted

“Plaintiffs request to determine the value of the Property at $60,000.00 is hereby GRANTED.”

Request to declare interest wholly unsecured (The debtors and plaintiffs) Denied

“Plaintiffs request to declare AEELA’s interest in the Property is wholly unsecured is hereby DENIED.”

Request to classify second mortgage claim as unsecured (The debtors and plaintiffs) Granted

“Plaintiffs request to determine that AEELA’s claim for its second mortgage be classified as unsecured is hereby GRANTED.”

Firstbank PR v. Wigberto Lugo Mender Chapter 7 Trustee (In re New York Mortgage Bankers Inc.)
· 2015-04-13
Motion to dismiss counterclaim (FirstBank Puerto Rico) Granted

“Plaintiffs Motion to Dismiss is GRANTED. Clerk to enter Judgment.”

In re Triple A & R Capital Investment, Inc.
· 2014-10-09
Motion for relief from stay (PRLP 2011 Holdings LLP) Granted

“The Motion to lift stay filed by PRLP [Dkt. No. 36] is GRANTED.”

In re Millan
· 2014-05-21
Motion for reconsideration (The debtor) Denied

“the Motion to Alter or Amend Order and/or For Reconsideration of Dismissal filed by Debtor shall be, and it hereby is, DENIED.”

In re Burgos
· 2014-05-12
Motion to dismiss case (The Chapter 11 trustee and Oriental Bank) Granted

“the Debtors’ case shall be, and it hereby is, DISMISSED.”

In re Ramos
· 2014-05-01
Motion to avoid judicial lien (Ms. Rosado) Granted

“Ms. Rosado’s request to avoid lien shall be, and it hereby is, GRANTED.”

In re Chispito, Inc.
· 2013-02-27
Motion for retroactive relief from stay (Jose Roberto Hawayek Alemany) Granted

“the Motion for Retroactive Relief From Automatic Stay filed on October 11, 2012 [Dkt. No. 23] shall be, and it hereby is, GRANTED.”

Caseload & timing

From public federal docket records for this judge.

All five sampled matters were terminated; durations ranged from 350 to 2,958 days, with a median of 1,222 days.

A historical record

Judge Tester no longer hears cases. This profile stays available as a record of how they ruled. If you're preparing for a matter, start from the court's current bench.