Draft Final Decree Motion

Skill: Draft Final Decree Motion

1. Subject-matter triage

• This task is a paired bankruptcy closing package: draft the motion first, then the companion proposed order.
• Treat closure under § 350(a) and Rule 3022 as the organizing frame, with the plan-confirmation record supplying the factual basis.
• If the source set does not show that the case is ready to close, the motion should say so precisely and tie any requested closure to satisfaction of the remaining administration steps.

2. Failure modes the skill is correcting

• Misstating the case posture by implying all administration is complete when fee matters, reports, disputed claims, reserves, or other wrap-up items remain open.
• Omitting the practical closure provisions courts expect in a final decree order, including tailored retained-jurisdiction language and a statement preserving the discharge injunction’s effect.
• Drafting only one document instead of both required deliverables.
• Collapsing distinct post-confirmation tasks into a vague “substantially consummated” assertion without showing the factual steps that support closure.
• Using a generic closing order that does not track the actual status of the case and its remaining administrative work.

3. Legal frameworks / domain conventions that apply

• Final decree authority comes from Bankruptcy Code § 350(a) and Bankruptcy Rule 3022; closure turns on whether the estate has been fully administered.
• Substantial consummation is commonly analyzed through the plan’s implementation milestones, including contemplated transfers, assumption of management or business functions, and commencement of distributions.
• Open administration items often include U.S. Trustee fees, periodic reporting, professional fee applications, disputed claims, litigation or settlement administration, reserves, and any continuing plan obligations.
• A closing order should be limited to matters that may properly survive closure, should not overreach into merits rulings, and should preserve only the jurisdiction necessary to administer residual case issues.
• Any statement about the discharge injunction should be tied to the applicable Bankruptcy Code discharge provisions and the effect of closure on those injunctions, rather than left implicit.
• Legal propositions in the motion should be supported by named authority; do not state closure standards or retained-jurisdiction propositions without identifying the statute, rule, or other controlling source.

4. Analytical scaffolds

• Start by identifying every remaining administration item visible in the source documents.
• For each item, state three things: what it is, whether it is complete or still pending, and what must occur before closure if it remains open.
• Separate factual completion from legal readiness: a case may be operationally near completion yet still require discrete final steps before entry of the decree.
• If the record supports substantial consummation, explain the specific implementation steps shown by the documents rather than reciting the label alone.
• If the record does not clearly support closure, draft the motion conservatively and frame the requested order to account for any unresolved administration issue.
• In the proposed order, include only closure-related decretal relief, any necessary condition precedent to closure, a narrow retained-jurisdiction clause for residual matters, and an express discharge-injunction preservation provision.

5. Vertical / structural / temporal relationships

• Organize the motion in chronological sequence: confirmation and implementation, current administration status, remaining tasks, then legal standard and requested relief.
• Treat post-confirmation events as the evidence base for closure; do not infer completion from confirmation alone.
• Distinguish between pre-closure obligations that must be satisfied before the decree enters and post-closure matters that the court may still need to supervise.
• Where multiple open items exist, address them one by one so the reader can see which matters are finished, which are pending, and which are being reserved.

6. Output structure conventions

• Produce two documents: the motion for entry of final decree and the proposed order.
• Motion structure should follow a conventional bankruptcy closing format: caption and introduction; background and procedural history; case administration and plan status; discrete treatment of remaining open items; legal standard under § 350(a) and Rule 3022; request for entry of a final decree.
• The motion should sound like a court filing, not a memo; use factual assertions supported by the source documents and legal statements tied to named authority.
• The proposed order should use a standard caption, make concise findings or recitals sufficient to support closure, then enter the decree and any narrowly tailored closure provisions.
• Include a retention-of-jurisdiction paragraph only for matters that customarily survive closure and are connected to administration of the case, not for a blanket reservation of all conceivable disputes.
• Include an express statement addressing the continued effect of the discharge injunction after entry of the final decree.
• Ensure the primary deliverable exists and is the operative filing, and confirm that the companion order is also complete and non-empty before finishing.