Martínez v. Novo Nordisk, Inc.  ·  2018-04-11  ·  D. Puerto Rico  ·  pin 522 F.3d at 1080

"[B]ecause of these differences between Chapter 7 and Chapter 13 bankruptcies, the four circuit courts to consider this issue have all concluded that Chapter 13 debtors have standing to bring claims in their own name on behalf of the bankruptcy estate."