The U.S. District Court for the Southern District of New York, on April 23, 2019, denied a litigation trustee's motion for leave to file a sixth amended complaint that would
Safe Harbor Shields Shareholders In Tribune Fraudulent Transfer Litigation
The U.S. District Court for the Southern District of New York denied a litigation trustee's motion for leave to file a sixth amended complaint that would have asserted constructive fraudulent transfer claims against 5,000 Tribune Company shareholders. The safe harbor of Bankruptcy Code §546(e) barred the trustee's proposed claims.

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