The following excerpt is from In re Residential Capital, LLC, Case No. 12-12020 (MG) (Bankr. S.D.N.Y. 2014):
While "[t]he circumstances under which the doctrine could be applied are far from clear," Young v. U.S. Dep't of Justice, 882 F.2d 633, 639 (2d Cir. 1989), many courts in this circuit have
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