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Jennifer L. Seidman Jones Day

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Construing "substantial contribution" under Section 503(b)(3)(D) *

USA - June 12 2012
In keeping with the courts’ narrow construction of what constitutes “substantial contribution” in a chapter 11 case, an Ohio bankruptcy court in In re AmFin Financial Corp., 2012 WL 652018 (Bankr. N.D. Ohio Feb. 28, 2012), denied administrative-expense priority to the fees and expenses of the holders of approximately $100 million in senior notes (the “Senior Noteholders”) issued by debtor AmFin Financial Corporation (“AFC”).