October 2014—Colorado Bankruptcy Judge junks liens asserted against estate property. Brian Fletcher and Andy Johnson successfully defended the trustee in Old Town North from bad liens. The Bankruptcy Court held that a deed of trust must contain a description of the property to encumber it. While that may sound obvious, after Sender v. Cygan and the resulting amendments to Colo. Rev. Stat. § 38-35-122, what had to be in a deed of trust was an open question. The Bankruptcy Court also held that equitable subrogation cannot survive the rights of a prior judgment lien creditor under 11 U.S.C. § 544. Both rulings were issues of first impression.