Delaware Bankruptcy Memo
Conflicting Rulings on Rule 2019 Disclosure Requirements
February 1, 2010
The United States Bankruptcy Court for the District of Delaware recently issued two important, but conflicting, rulings on the disclosure requirements of Rule 2019 of the Federal Rules of Bankruptcy Procedure. Rule 2019 is critically important to hedge fund managers and others who trade in distressed securities using proprietary investment practices. These two rulings highlight the uncertainty that currently exists regarding the applicability of Rule 2019's disclosure requirements.
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