Jackson v. Le Centre On Fourth LLC (In re Le Centre On Fourth LLC), ___F4th___ (11th Cir. Nov. 15, 2021), appeal No. 20-12785
11th Circuit Court of Appeals expands Espinosa case reasoning, to say that a debtor’s failure to give notice–as required by FRBP Rule 2002(c)(3)–to creditors, that the bankruptcy debtor’s proposed plan would give releases to non-debtor third parties, not just to the bankruptcy debtor, is NOT fatal, so long as the proposed Plan was served on all creditors, and the Plan stated that the Plan, if confirmed, would give release to non-debtor third parties, not just to debtor. The 11th Circuit decision said Circuit was analogizing to the reasoning of the Espinosa case.