In re Mitchell (Case No. 11-51653)
The Court denied the Trustee's motion, pursuant to 11 U.S.C. §363(f)(4), for private sale of realty and to transfer liens to proceeds of sale. The Court found that because the applicable statute of limitations prevented the Trustee from bringing an adversary proceeding to avoid the lien, the Trustee could not show that the lien was "in bona fide dispute." Moreover, the Trustee's motion was procedurally inadequate.