In re Galardi (Chapter 11 Case No. 22-50035, Adv. Case No. 24-5015)

The court was asked to consider whether the pro se plaintiff in an adversary proceeding should be held in contempt for filing a complaint against the liquidating trustee, as well as moving to amend the complaint to re-add the trustee as a defendant after previously dismissing him. The liquidating trustee moved for contempt on the grounds that the plaintiff’s actions violated a covenant not to sue in a court-approved settlement agreement reached earlier in the main chapter 11 case.  The court held the plaintiff in contempt for violating the order approving the settlement agreement and awarded compensatory sanctions in the form of attorneys’ fees. The court also held that the motion for contempt was appropriate as filed in the adversary proceeding even though the order the plaintiff violated was entered in the main chapter 11 case.

Date: 
Friday, August 8, 2025