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In re: Global One Media (Shapiro v. Newtek Small Business Finance) BAP - 9th Circuit (4/2/25) The bankruptcy court ruled that Newtek perfected its security interest in Debtor's personal property, which is located in Nevada and New Mexico, by filing UCC-1 financing statements in those two states. The court reversed holding that Newtek had to file a UCC-1 in Delaware, Debtor's state of incorporation, to perfect its security interest.
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