In re: James Jin Qing Li

CourtUnited States Bankruptcy Appellate Panel for the Ninth Circuit
DecidedMarch 12, 2018
DocketNC-17-1062-STaB
StatusUnpublished

This text of In re: James Jin Qing Li (In re: James Jin Qing Li) is published on Counsel Stack Legal Research, covering United States Bankruptcy Appellate Panel for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: James Jin Qing Li, (bap9 2018).

Opinion

FILED MAR 12 2018 1 NOT FOR PUBLICATION SUSAN M. SPRAUL, CLERK U.S. BKCY. APP. PANEL 2 OF THE NINTH CIRCUIT

3 UNITED STATES BANKRUPTCY APPELLATE PANEL 4 OF THE NINTH CIRCUIT 5 In re: ) BAP No. NC-17-1062-STaB ) 6 JAMES JIN QING LI, ) Bk. No. 3:12-bk-33630 ) 7 Debtor. ) ______________________________) 8 ) JAMES JIN QING LI, ) 9 ) Appellant, ) 10 ) v. ) MEMORANDUM* 11 ) MIKE ROSEN, ) 12 ) Appellee. ) 13 ______________________________) 14 Argued and Submitted on January 25, 2018 at San Francisco, California 15 Filed – March 12, 2018 16 Appeal from the United States Bankruptcy Court 17 for the Northern District of California 18 Honorable Hannah L. Blumenstiel, Bankruptcy Judge, Presiding 19 Appearances: Bradley Kass of Kass & Kass Law Offices argued for appellant; Lawrence D. Miller argued for appellee. 20 21 Before: SPRAKER, TAYLOR and BRAND, Bankruptcy Judges. 22 23 24 25 26 * This disposition is not appropriate for publication. 27 Although it may be cited for whatever persuasive value it may have (see Fed. R. App. P. 32.1), it has no precedential value. 28 See 9th Cir. BAP Rule 8024-1. 1 INTRODUCTION 2 In terms of standard of proof and procedure, there are 3 significant differences between relief from stay and lien 4 avoidance proceedings. This case highlights those differences. 5 The debtor, James Jin Qing Li, argues that the bankruptcy court 6 erroneously terminated the automatic stay to permit execution on 7 an invalid judgment lien. However, motions for relief from the 8 automatic stay are summary proceedings and may be granted upon 9 demonstration of a colorable claim. Challenges to the validity 10 of a creditor’s lien, in contrast, ordinarily require the 11 commencement and prosecution of an adversary proceeding under 12 Rule 7001(2).1 13 The bankruptcy court found that the moving creditor’s claim 14 was colorable. It did not attempt to decide whether the 15 creditor’s lien was valid. Rather, the court specifically left 16 that question for another day. In the context of relief from 17 stay jurisprudence, this was wholly appropriate. Accordingly, we 18 AFFIRM. 19 FACTS 20 Creditor Mike Rosen filed his relief from stay motion in 21 October 2016. The motion was one salvo in a long history of 22 litigation between the parties. Rosen sought relief from stay so 23 that he could enforce a judgment lien against debtor James Jin 24 Qing Li’s leasehold interest in a restaurant space located in a 25 1 26 Unless specified otherwise, all chapter and section references are to the Bankruptcy Code, 11 U.S.C. §§ 101-1532, and 27 all "Rule" references are to the Federal Rules of Bankruptcy Procedure, Rules 1001-9037. All "Civil Rule" references are to 28 the Federal Rules of Civil Procedure.

2 1 shopping center in Daly City, California. 2 Rosen also sought to lift the automatic stay to file a 3 fraudulent transfer action against Li’s former spouse Xiao Yan 4 Chen. Rosen claimed that, days before commencing his 2012 5 chapter 7 bankruptcy case, Li fraudulently transferred to Chen 6 two parcels of real property; one located in Milbrae, California, 7 and the other located in Daly City, California. Notwithstanding 8 the transfers, Rosen believed that Li, and presumably his 9 bankruptcy estate, continued to have an interest in the 10 transferred property that necessitated relief from the stay 11 before he could pursue a claim to recover this property in a 12 nonbankruptcy forum. 13 In his papers filed in support of his relief from stay 14 motion, Rosen explained the source of his lienholder’s interest: 15 a judgment dated July 31, 2012, in favor of Spondulix Company, 16 Inc. and against Li and other defendants in the amount of 17 $872,304.95. Spondulix assigned this judgment to Rosen on March 18 8, 2013 (the “Spondulix Judgment”).2 Prior to the assignment, 19 Spondulix recorded in the official records of Alameda County an 20 abstract of judgment to perfect a judgment lien against the 21 judgment debtors’ real property. Of particular note, the form 22 abstract of judgment has a space for the judgment creditor to 23 enter the last four digits of the judgment debtor’s Social 24 Security number, but Spondulix checked the box indicating that 25 Li’s Social Security number was unknown. Rosen contends that a 26 27 2 The relationship between Rosen and Spondulix, if any, is 28 undisclosed.

3 1 judgment lien arose upon the recording of the abstract and 2 attached to the two parcels Li later transferred to Chen, as well 3 as his remaining leasehold interest. 4 Li opposed the relief from stay motion by filing a 5 “preliminary” memorandum of points and authorities. Li asserted 6 that the relief from stay motion was duplicative of a prior 7 motion filed by Rosen and his spouse and granted in 2013 8 (Bk. Dkt., Doc. No. 57). Li further maintained that any 9 fraudulent transfer claims belonged to his bankruptcy estate and 10 thus Rosen lacked standing to pursue those claims (and also to 11 seek relief from stay to pursue those claims). As for the 12 leasehold interest in the restaurant space, Li argued that his 13 interest had no value, so stay relief should be denied. 14 Li also asserted that Rosen was barred from pursuing the 15 fraudulent transfer claims, and from enforcing the Spondulix 16 Judgment, in light of a settlement agreement between Rosen and 17 Li. Li’s chapter 7 trustee was not a party to the settlement 18 agreement. Still, on July 12, 2016, the bankruptcy court had 19 approved the settlement agreement. Pursuant to the settlement 20 agreement, the parties released and resolved all pending claims 21 and actions they held against each other with certain specific 22 exceptions. Significantly, the enumerated exceptions included: 23 (1) Rosen’s rights as an assignee of judgment creditor Spondulix; 24 and (2) Rosen’s rights, if any, in Li’s leasehold interest in the 25 restaurant space.3 26 3 27 The bankruptcy court subsequently vacated its July 12, 2016 settlement approval order to the extent it could have 28 (continued...)

4 1 At the relief from stay hearing, Li raised a new argument. 2 He contended that Spondulix’s abstract of judgment was invalid 3 and unenforceable because it did not include Li’s Social Security 4 number. Therefore, Li reasoned, there was no basis for relief 5 from the stay. Rosen acknowledged at the hearing that California 6 law required the creditor to include the debtor’s Social Security 7 number if known, and that Spondulix indisputably knew Li’s Social 8 Security number because it was included in Spondulix’s complaint. 9 However, Rosen argued that Li lacked standing to assert the 10 invalidity of the abstract of judgment. 11 The bankruptcy court was not persuaded by any of Li’s 12 arguments. In particular, it was not swayed by the argument that 13 the allegation of a fatal defect in the abstract of judgment was 14 something it should determine as part of the relief from stay 15 motion. Rather, the bankruptcy court noted that either Li, or 16 his former spouse, could raise (and litigate) the validity of his 17 judgment lien as part of whatever state court proceedings 18 followed the granting of relief from stay. The bankruptcy court 19 entered its order granting relief from stay on December 14, 2016. 20 Li timely filed a motion under Civil Rules 59 and 60 seeking 21 3 (...continued) 22 affected Rosen’s rights as Spondulix’s assignee. See Order 23 Granting Motion to Set Aside Order Dismissing Adversary Complaint (Sept. 1, 2016) at p. 2.

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In re: James Jin Qing Li, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-james-jin-qing-li-bap9-2018.