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Case Digests

Jurisdiction

Scott Carrington Matthew appeals an order (1) vacating a default judgment entered in Matthew’s favor against Elite Team Auto Brokers, LLC, its owners, and a manager (collectively, Elite) and (2) dismissing Matthew’s action without prejudice for lack of personal jurisdiction under WIS. STAT. § 801.05 (2017-18).

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Statutory Interpretation – Bankruptcy – UCC

This interlocutory bankruptcy appeal presents a matter of first impression for our court: whether Illinois’s version of Article 9 of the Uniform Commercial Code requires a financing statement to contain within its four corners a specific description of secured collateral, or if incorporating a description by reference to an unattached security agreement sufficiently “indicates” the collateral.

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