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On July 25, 2011, the United States Court of Appeals for the Ninth Circuit in In re Flamingo 55, Inc., No. 10-15755, 2011 U.S. App. Lexis 15285 (9th Cir. July 25, 2011), held that a creditor who is a joint borrower rather than a surety, guarantor, or accommodation co-maker, was not entitled to subrogation under 11 U.S.C. 509(a
