In Re Reynolds, 2012 WL 1190296

Debtors object to five proofs of claim (1-1, 4-1, 5-1, 10-1, 11-1) filed by major creditors.
Claims correspond to debts listed on Debtors' Schedule F and acknowledged as owed.
Debtors did not mark the debts as contingent, unliquidated, or disputed.
Attachments to claims were account summaries, not the original writings required by Rule 3001(c)(1).
Rule 3001(c)(2) (2011 revision) adds sanctions but does not authorize disallowance solely for missing documents.
Court applies revised Rule 3001; ultimately disallowance requests are denied and claims are allowed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to attach documents justifies disallowance under Rule 3001(c)	Reynolds objects based on lack of attached writings.	Creditors rely on Kirkland to disallow for noncompliance.	No disallowance; Rule 3001(c)(2)(D) penalties apply only to evidence, not disallowance.
Effect of the 2011 Rule 3001 revision on Kirkland	Kirkland control remains despite revision.	Revisions supersede Kirkland's approach.	Kirkland's rule remains superseded; disallowance not authorized solely for missing docs under revised rule.
Whether judicial estoppel precludes disallowance	Debtors shouldn't be bound by earlier admission of debt.	Estoppel prevents inconsistent positions after schedules show liability.	Judicial estoppel precludes disallowance; Debtors cannot rely on procedural grounds to defeat admitted debts.
Final disposition of the five claims	Disallowance of all five claims.	Evidence-based grounds lacking; allow claims.	Claims allowed in full; disallowances denied.

Nishimatsu Construction Co. v. Houston National Bank, 515 F.2d 1200 (5th Cir. 1975) (default requires sufficient grounds in pleadings)
Pitts v. Seneca Sports, Inc., 321 F. Supp. 2d 1353 (S.D. Ga. 2004) (pleadings admitted facts; conclusions not granted)
United Student Aid Funds, Inc. v. Espinosa, 130 S. Ct. 1367 (Supreme Court 2010) (confirming limits of review when creditors default)
In re Kirkland, 361 B.R. 199 (Bankr. D. N.M. 2007) (rule 3001 documentation; burden on claimant)
B-Line, LLC v. Kirkland (In re Kirkland), 379 B.R. 341 (10th Cir. BAP 2007) (Kirkland affirmed raised rule 3001 concerns)
Caplan v. B-Line, LLC (In re Kirkland), 572 F.3d 838 (10th Cir. 2009) (post-Kirkland appellate framing)
Landgraf v. USI Film Products, 511 U.S. 244 (U.S. 1994) (prospective application of procedural rules)
New Hampshire v. Maine, 532 U.S. 742 (U.S. 2001) (factors for judicial estoppel applicability)
In re Brown, 2012 WL 384886 (Bankr. D. Colo. 2012) (illustrates Kirkland concern in practice)
Central Virginia Community College v. Katz, 546 U.S. 356 (U.S. 2006) (bankruptcy estate distribution principles)