Pleading Fraudulent Conveyances: Federal vs. New York State Requirements

(Excerpt) Fraudulent conveyances are transfers of a debtor’s property made to defraud, burden, and unfairly place the property out of reach of the creditor. Such transfers are illegal and therefore prohibited under both federal and New York State law. Federal fraudulent conveyance law, the United States Bankruptcy Code (the “Bankruptcy Code”), recognizes two different types of fraudulent conveyances: intentional (“actual”) fraudulent transfers and constructive fraudulent transfers. Each of these fraudulent transfers require different pleading standards. These two types of fraud are recognized in New York, as well. If these fraudulent conveyances can be proven, both federal and state law allow for trustees to avoid these transfers. Both similarities and differences exist between fraudulent transfer pleading standards under federal law and New York State law. New York recently adopted a new fraudulent conveyance statute, the Uniform Voidable Transactions Act (the “UVTA”). The UVTA became effective in April 2020 and is consistent with much of the Bankruptcy Code. This memorandum compares the fraudulent conveyance statutes and pleading requirements under federal law to the standards imposed under New York State law. Part I of this memorandum first discusses the general pleading standards when filing a complaint in federal court. It also identifies and defines the two types of fraudulent conveyances prohibited under the Bankruptcy Code -- intentional fraudulent conveyances and constructive fraudulent conveyances -- and addresses the different pleading standards for each type of fraud. Part II of this memorandum addresses the pleading requirements for complaints filed in New York State, and then compares the pleading standards under New York’s old statute, the Uniform Fraudulent Conveyance Act (the “UFCA”), to its new statute, the UVTA

A Comprehensive Patient-Derived Xenograft Collection Representing the Heterogeneity of Melanoma

Therapy of advanced melanoma is changing dramatically. Following mutational and biological subclassification of this heterogeneous cancer, several targeted and immune therapies were approved and increased survival significantly. To facilitate further advancements through pre-clinical in vivo modeling, we have established 459 patient-derived xenografts (PDX) and live tissue samples from 384 patients representing the full spectrum of clinical, therapeutic, mutational, and biological heterogeneity of melanoma. PDX have been characterized using targeted sequencing and protein arrays and are clinically annotated. This exhaustive live tissue resource includes PDX from 57 samples resistant to targeted therapy, 61 samples from responders and non-responders to immune checkpoint blockade, and 31 samples from brain metastasis. Uveal, mucosal, and acral subtypes are represented as well. We show examples of pre-clinical trials that highlight how the PDX collection can be used to develop and optimize precision therapies, biomarkers of response, and the targeting of rare genetic subgroups

Youth, violence and non-injection drug use: nexus of vulnerabilities among lesbian and bisexual sex workers

Despite increasing evidence of enhanced HIV risk among sexual minority populations, and sex workers in particular, there remains a paucity of epidemiological data on the risk environments of sex workers who identify as lesbian or bisexual. Therefore, this short report describes a study that examined the individual, interpersonal and structural associations with lesbian or bisexual identity among sex workers in Vancouver, Canada. Analysis drew on data from an open prospective cohort of street and hidden off-street sex workers in Vancouver. Bivariate and multivariable logistic regression were used to examine the independent relationships between individual-, interpersonal, work environment- and structural-factors and lesbian or bisexual identity. Of the 510 individuals in our sample, 95 [18.6%] identified as lesbian or bisexual. In multivariable analysis, reporting non-injection drug use in the last 6 months (adjusted odds ratio [AOR]= 2.89; 95% confidence intervals [CI]= 1.42, 5.75), youth ≤ 24 years of age (AOR= 2.43; 95% CI = 1.24, 4.73) and experiencing client-perpetrated verbal, physical and/or sexual violence in the last 6 months (AOR= 1.85; 95% CI= 1.15, 2.98) remained independently associated with lesbian/bisexual identity, after adjusting for potential confounders. The findings demonstrate an urgent need for evidence-based social and structural HIV prevention interventions. In particular, policies and programs tailored to lesbian and bisexual youth and women working in sex work, including those that prevent violence and address issues of non-injection stimulant use are required

Genetic and Genomic Characterization of 462 Melanoma Patient-Derived Xenografts, Tumor Biopsies, and Cell Lines

Summary: Tumor-sequencing studies have revealed the widespread genetic diversity of melanoma. Sequencing of 108 genes previously implicated in melanomagenesis was performed on 462 patient-derived xenografts (PDXs), cell lines, and tumors to identify mutational and copy number aberrations. Samples came from 371 unique individuals: 263 were naive to treatment, and 108 were previously treated with targeted therapy (34), immunotherapy (54), or both (20). Models of all previously reported major melanoma subtypes (BRAF, NRAS, NF1, KIT, and WT/WT/WT) were identified. Multiple minor melanoma subtypes were also recapitulated, including melanomas with multiple activating mutations in the MAPK-signaling pathway and chromatin-remodeling gene mutations. These well-characterized melanoma PDXs and cell lines can be used not only as reagents for a large array of biological studies but also as pre-clinical models to facilitate drug development. : Garman et al. have characterized melanoma PDXs and cell lines described in Krepler et al. (see the related paper in this issue of Cell Reports), identifying major and minor subtypes, some of which were previously not well defined, targeted and immunotherapy resistance, and tumor heterogeneity, creating a set of reagents for future drug discovery and biological studies. Keywords: melanoma, patient-derived xenografts, massively parallel sequencing, cell line

A Comprehensive Patient-Derived Xenograft Collection Representing the Heterogeneity of Melanoma

Summary: Therapy of advanced melanoma is changing dramatically. Following mutational and biological subclassification of this heterogeneous cancer, several targeted and immune therapies were approved and increased survival significantly. To facilitate further advancements through pre-clinical in vivo modeling, we have established 459 patient-derived xenografts (PDX) and live tissue samples from 384 patients representing the full spectrum of clinical, therapeutic, mutational, and biological heterogeneity of melanoma. PDX have been characterized using targeted sequencing and protein arrays and are clinically annotated. This exhaustive live tissue resource includes PDX from 57 samples resistant to targeted therapy, 61 samples from responders and non-responders to immune checkpoint blockade, and 31 samples from brain metastasis. Uveal, mucosal, and acral subtypes are represented as well. We show examples of pre-clinical trials that highlight how the PDX collection can be used to develop and optimize precision therapies, biomarkers of response, and the targeting of rare genetic subgroups. : Krepler et al. have established a collection of melanoma patient-derived xenografts (PDX). Melanoma is a very heterogeneous cancer, and this large collection includes even rare subtypes and genetic aberrations in sufficient numbers. Multiple PDX from therapy-resistant patients are characterized and tested in pre-clinical trials for second line therapies. Keywords: melanoma, patient-derived xenografts, targeted therapy, immune checkpoint blockade, melanoma brain metastasis, in vivo models, BRAF inhibitor resistance, ERK inhibitor, MDM2 inhibitor, PI3K beta inhibito

Engineered nanotopography on electrospun PLLA microfibers modifies RAW 264.7 cell response

In this study, we created a new method of electrospinning capable of controlling the surface structure of individual fibers (fiber nanotopography). The nanotopographical features were created by a phase separation in the fibers as they formed. To control the phase separation, a nonsolvent (a chemical insoluble with the polymer) was added to an electrospinning solution containing poly-l-lactic acid (PLLA) and chloroform. The nanotopography of electrospun fibers in the PLLA/chloroform solution was smooth. However, adding a small weight ( \u3c 2% of total solution) of a single nonsolvent (water, ethanol, or dimethyl sulfoxide) generated nanoscale depressions on the surface of the fibers unique to the nonsolvent added. Additionally, nanoscale depressions on electrospun fibers were observed to change with dimethyl sulfoxide (DMSO) concentration in the PLLA/chloroform solution. A nonlinear relationship was found between the concentration of DMSO and the number and size of nanotopographical features. The surface depressions did not alter the hydrophobicity of the scaffold or degradation of the scaffold over a two-day period. To determine if fiber nanotopography altered cell behavior, macrophages (RAW 264.7 cells) were cultured on fibers with a smooth nanotopography or fibers with nanoscale depressions. RAW 264.7 cells spread less on fibers with nanoscale depressions than fibers with a smooth topography (p \u3c 0.05), but there were no differences between groups with regard to cell metabolism or the number of adherent cells. The results of this study demonstrate the necessity to consider the nanotopography of individual fibers as these features may affect cellular behavior. More importantly, we demonstrate a versatile method of controlling electrospun fiber nanotopography. © 2013 American Chemical Society