1. 345 Some of these courts found that the Midlantic majority itself was supportive of the distinction between liquidating and operating Estate Representatives. 346 Any reference to actual language used by the majority is conspicuously lacking. Other courts have cited Justice Rehnquist's dissent as authoritative. 347 Cases also began to rely upon the predecessor to 28 U.S.C. � 959(a) for further support;959(b) applied to liquidating Estate Representatives. The majority of courts (in both bankruptcies and receiverships) have exempted liquidating Estate Representatives from 28 U.S.C. � 959(b)
2. Federal Courts. Review. Unexplained Dismissal without Prejudice of Intervenor's Counterclaims Seeking Injunctive Relief Is Appealable. Stewart-Warner Corp. v. Westinghouse Elec. Corp. (2d Cir. 1963)