Greif & Co. v. Shapiro (In re Western Funding Inc.), 550 B.R. 841 (9th Cir.BAP 2016) (“Greif”)
Greif & Co. v. Shapiro (In re Western Funding Inc.), 550 B.R. 841 (9th Cir.BAP 2016) (“Greif”): The U.S. Bankruptcy Appellate Panel for the Ninth Circuit (the “9th Circuit BAP”) held that the standards for approving a settlement agreement under Fed. R. Bankr. P. 9019(a) did not apply per se to a post-confirmation settlement agreement between a creditor and the liquidating trustee (the “Liquidating Trustee”), as liquidating trustees do not constitute “trustees” for purposes of the Bankruptcy Code and Bankruptcy Rules.