Law360, New York ( August 17, 2011, 1:42 PM EDT) -- 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. (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). ...
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