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" ... Finally, we arrive at the last issue which is the awarding of attorney's fees in fraudulent transfer cases. The UFTA/UVTA does not expressly provide for the award of attorney's fees, but there is statutory language that allows for "any other relief the circumstances may provide" in § 7(a)(3)(iii), and then the "Supplemental Provisions" section essentially allows a court to import into a fraudulent transfer case other laws as appropriate. The result is a confusing mélange of rules: Some state permit attorney's fees in fraudulent transfer cases while others don't, some states permit attorney's fees where the underlying case was of a particular type (such as breach of contract cases where attorney's fees are usually awardable), but not in others. And then some states permit attorney's fees to be awarded against both the debtor and the transferee, while others restrict such awards to only against the debtor. ... "
" ... The hard takeaway from this case is that attorney fees might, or might not, be awardable in an UFTA/UVTA case under the "any other relief the circumstances may require" language of § 7, depending on whether the courts of a particular state have bought into that argument. That was the decision before Judge Boulware, and, for what it is worth, your writer thinks he reached the correct result. ... "