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The article explores some of the significant trends Scott has seen over the last 30 years that he has been representing middle-market debtors in Chapter 11 cases in New York City with respect to what the Bankruptcy Code denominates as “single asset real estate” cases (SARE). He notes that SAREs make up a significant portion of Chapter 11 cases, are usually filed voluntarily and generally involve a two-party dispute between the owner of the real estate and the mortgagee.