The following excerpt is from Mammo v. Sako (In re Sako), Adversary Proceeding No. 13-90210-CL, Bankruptcy Case No. 13-05182-CL7 (Bankr. S.D. Cal. 2015):
Further, "[t]he federal prejudgment interest rate applies to actions brought under federal statute, such as bankruptcy proceedings, unless the equites of the case require a different rate." Banks v. Gill Distribution Centers, Inc. (In re Banks), 263 F.3d 862, 871 (9th Cir. 2001) (citing Nelson v. EG & G Energy Measurements Group, Inc., 37 F.3d 1384, 1392 (9th Cir. 1994)). And, in particular, an action under 523(a)(2)(A) is a product of federal law engendering federal prejudgment interest. In re Eberts, No. CV 11-08827-MWF, 2013 WL 1248637, at *10-11 (C.D. Cal., March 27, 2013).
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