In Mendelsohn v. Dole Fresh Fruit Co. (In re Barnett Corp.), the Bankruptcy Court for the Eastern District of New York conditionally granted an adversary proceeding defendant’s motion to dismiss a complaint asserting, among other things, federal and state fraudulent transfer claims on the basis that the plaintiff failed to meet federal pleading standards. In December 2022, Barnett Corp. and Barnett Forest LLC (collectively, the debtors) filed Chapter 7 petitions.