In re Duckworth
In re Duckworth, ___ F3d ___, 2014 Westlaw 7686549 (7th Cir. 2014): The Seventh Circuit has held that a lender’s security interest in crops and equipment was void because the security agreement referred to a promissory note dated “December 13,” instead of “December 15,” the correct date of execution; further, incorporation by reference did not cure the defect because the definitions contained in the document were circular. Case is a warning to secured creditors to make sure that security agreements and other transactional documents are accurate.