Sdvf, LLC v. Cozzia USA LLC

BACKGROUND

Because this case’s procedural history is complicated, we will only outline the key facts necessary to resolve this appeal. In August 2018, Brookstone Holdings Corp. filed for Chapter 11 bankruptcy protection in the Delaware Bankruptcy Court. The company’s reorganization plan named META Advisors LLC as a liquidating trustee, who was charged with liquidating and distributing the company’s assets to creditors. The liquidating trustee could also sue to recover assets. META filed an adversary action against Cozzia—a company that provided merchandise sold at Brookstone—in Delaware Bankruptcy Court. META sought to avoid and recover certain payments from SDVF, LLC V. COZZIA USA LLC

Brookstone that allegedly were preferential, fraudulent, or post-petition under the Bankruptcy Code. In February 2021, the Delaware Bankruptcy Court entered default judgment against Cozzia for over $300,000. No. 19-51189-BLS (Bankr. D. Del.), at ECF 10. Then in December 2021, META assigned its title and rights in this default judgment to SDVF, LLC, which became the new judgment creditor of the $300,000-plus default judgment. SDVF then filed a notice of META’s…