What of direct creditor claims after 'Gheewalla'?

The strategy occurs in bankruptcy cases around the country. Trustees or committees look to recover funds for creditors of a bankrupt debtor. To avoid affirmative defenses to a debtor/company claim or problems quantifying the damages suffered by the debtor, trustees get assignments from creditors of claims that creditors have against third parties. Many observers believed the Delaware Supreme Court's Gheewalla decision would stop or curtail that practice. But it may not have slammed the door shut.

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