The following excerpt is from In re Grosso, 9 BR 815 (Bankr. N.D.N.Y. 1981):
The fact that such a cause of action is brought in the federal bankruptcy court is not a ground to ignore this expressly stated form of action. If successful, a plaintiff will prove the existence of a trust which is property outside the debtor's estate. 541(c)(2) of the Bankruptcy Code, 11 U.S.C. 541(c)(2); see, Selby v. Ford Motors Company, 590 F.2d 642, 648 (6th Cir. 1979). Repetitive subsequent litigation by similarly situated creditor-parties can be avoided. But for the amount of the trust claim and its incurrence, all beneficiaries will have numerous identical items of proof.
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