Bankruptcy Client Alerts

The court in Black Sky Capital, LLC v. Cobb (2017) held that Section 580d does not preclude a "sold-out" junior lienholder from seeking a deficiency judgment, even when the same lender holds both the senior and junior liens. While Black Sky was positive for lenders, the case created a split of opinion on this issue among courts of appeal, which could only be resolved by the California Supreme Court. read more

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