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After Six, Inc. v. Sharpe's Formal Specialists, Inc. (In re After Six, Inc.)

Citations: 179 B.R. 59; 1995 U.S. Dist. LEXIS 3440Docket: No. 95-CV-0021; Bankruptcy No. 93-11150S; Adv. No. 94-0940

Court: District Court, E.D. Pennsylvania; March 16, 1995; Federal District Court

Narrative Opinion Summary

In the case between After Six, Incorporated, a men's formal wear manufacturer, and Sharpe’s Formal Specialists, Inc. and Sharpe’s Formal Wear, Inc., the legal dispute centers around a claim for contractual damages amounting to approximately $178,000. After Six filed this complaint in the Bankruptcy Court for the Eastern District of Pennsylvania following its Chapter 11 filing in February 1993. Sharpe’s sought to withdraw the reference from the Bankruptcy Court for a jury trial, asserting the matter was a non-core proceeding as per 28 U.S.C. 157(d) and claiming an absolute right to a jury trial. However, the Bankruptcy Court, upon a motion for summary judgment by After Six, determined that Sharpe’s had waived its right to a jury trial and awarded partial summary judgment in favor of After Six. Consequently, the District Court denied Sharpe’s motion to withdraw the reference, as the issue of jury trial entitlement was not properly presented. The decision was issued as a Report and Recommendations to the District Court, which retains the authority to issue a final order on the matter, without taking a stance on the waiver of the jury trial right.

Legal Issues Addressed

Non-Core Proceedings in Bankruptcy

Application: Sharpe’s claimed the contractual damages dispute was a non-core proceeding under 28 U.S.C. 157(d), seeking to withdraw the reference to the Bankruptcy Court for a jury trial.

Reasoning: Sharpe’s sought to withdraw the reference to the Bankruptcy Court for a jury trial, claiming the matter is a non-core proceeding under 28 U.S.C. 157(d) and asserting an absolute right to a jury trial.

Waiver of Right to Jury Trial

Application: The Bankruptcy Court ruled that Sharpe’s had waived its right to a jury trial in the contractual damages dispute with After Six, Incorporated.

Reasoning: Following a motion for summary judgment by After Six, the Bankruptcy Court ruled that Sharpe’s had waived its right to a jury trial and awarded After Six partial summary judgment.

Withdrawal of Reference from Bankruptcy Court

Application: The District Court denied Sharpe’s motion to withdraw the reference to the Bankruptcy Court, as the issue of entitlement to a jury trial was not properly before them.

Reasoning: The District Court found no cause to grant Sharpe’s motion to withdraw the reference, concluding that the issue of jury trial entitlement was not properly before them.