What is the current state of the law in this circuit on the doctrine of Section 22 of the Civil Code of Civil Procedure?

MultiRegion, United States of America

The following excerpt is from In re Residential Capital, LLC, Case No. 12-12020 (MG) (Bankr. S.D.N.Y. 2014):

While "[t]he circumstances under which the doctrine could be applied are far from clear," Young v. U.S. Dep't of Justice, 882 F.2d 633, 639 (2d Cir. 1989), many courts in this circuit have

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