John B. Ordille, Inc. v. Lenny Perry’s Produce, Inc., No. 12-mc-54S, 2012 U.S. Dist. LEXIS 16148 (W.D.N.Y. Nov, 12, 2012)

(judicial review of bankruptcy court determination regarding two Perishable Agricultural Commodities Act (PACA) trust claims; first PACA creditor’s claim was disallowed because invoices were sent after delivery of produce and offered a term of “Net 30” which allowed defendant payment term of more than 30 days and extended term was not in writing; court upheld bankruptcy court’s denial of second creditor’s claim for attorney fees and collection costs for failing to satisfy a judgment because PACA does not support these costs).