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10th Circuit

BANKRUPTCY, ATTORNEY FEES - A Chapter 7 bankruptcy trustee brought an adversary proceeding against the debtors and their law firm to recover funds held by the law firm as retainer for post-petition legal services. The 10th Circuit found that the retainers are outside the debtors' estate, so the firm may not use pre-petition funds to pay post-petition fees. Affirmed. See ruling.

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