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Email On January 30, 2013, Judge Christopher Klein of the Bankruptcy Court for the Eastern District of California held that, pursuant to section 904 of the Bankruptcy Code, a municipal debtor is not required to seek court approval to enter into settlements with and make settlement payments to prepetition creditors during the pendency of its chapter 9 case. https://www.cadwalader.com/resources/clients-friends-memos/city-of-stockton-bankruptcy-court-holds-that-rule-9019-does-not-apply-to-chapter-9-debtors