of cooperation. Cf. N.Y. UCC §§ 9-601(a), 9-609(c). 20 . See also Ed Peters Jewelry Co. v. C & J Jewelry Co., 124 F.3d 252, 267 (1st Cir. 1997) (UCC "commercial reasonableness" and successor liability, noting that "existing case law overwhelmingly confirms that an intervening foreclosure sale affords an acquiring corporation no automatic exemption from successor liability”); Kaiser Found. Health Plan v. Clary & Moore, P.C., 123 F.3d 201, 207-09 (4th Cir. 1997) (successor liability); Stoumbos v. Kilimnik, 988 F.2d 949, 962 (9th Cir. 1993) ("The mere fact that the transfer of assets involved foreclosure on a security interest will not insulate a successor corporation from liability where other facts point to continuation."); cf. Orr v. Kinderhill Corp., 991 F.2d 31, 35-36 (2d Cir. 1993) (<HOLDING>); Halbhuber, Debt Restructurings (manuscript at
holding that a spouse was bound by a conveyance of community property to which she was not a party because of her knowledge and acquiescence to the conveyance holding that a general creditor does not have a property interest superior to defendants in any particular asset or funds until he has obtained some judgment and secures that asset or those funds holding bankruptcy courts cannot enter final judgment on fraudulent transfer claims holding that asset transfer to spinoff created in context of restructuring which favored new stockholders over judgment creditor constituted fraudulent conveyance holding that debtors cannot claim an exemption in a homestead after trustee avoided the transfer of the property as a fraudulent conveyance because the transfer by the debtors was voluntary