After Bartenwerfer, what now? Vicarious liability for fraud under Bankruptcy Code §523(a)(2)(A)

Wednesday, March 8, 12:30 pm - 1:30 pm Pacific via ZOOM

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Earn 1.0 CA CLE Hour

Meet the Speakers

Hon. Barry Russell


U.S. Bankruptcy Judge

Central District of California

Iain A. Macdonald


Macdonald | Fernandez LLP

J. Scott Bovitz


Bovitz & Spitzer

About the Program

On February 22, 2023, the U.S. Supreme Court issued its unanimous opinion in Bartenwerfer v. Buckley, 598 U. S. ____ (2023) (honest debtor/business partner/wife could not discharge claim arising from fraud of dishonest partner/husband under 11 U.S.C. §523(a)(2)(A), even though the debtor did now know of the partner's fraud). Hear from one of the lawyers (Iain Macdonald of San Francisco) who represented Mrs. Bartenwerfer at the U.S. Supreme Court. The Hon. Barry Russell and J. Scott Bovitz will provide their own views on the future of litigation under 11 U.S.C. §523(a)(2)(A). What did the opinion resolve? What issues remain?

This program is presented by the Bankruptcy section. The Bankruptcy section is chaired by Alphamorlai Kebeh. This program is chaired by Robert C. Aronoff. Find out more at www.bhba.org.

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CLE CREDIT: This activity has been approved for participatory Minimum Continuing Legal Education credit by the State Bar of California in the amount shown above and the Beverly Hills Bar Association certifies that this activity conforms to the standards for approved education activities prescribed by the rules and regulations of the State Bar of California governing minimum continuing legal education.


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