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On March 18, 2003, in Calka v. Chuu, 2003 U.S. Dist. Lexis 4090 (S.D.N.Y. 2003), the federal court issued an important decision under federal bankruptcy law. The court held that an adversary proceeding brought by a debtor tenant to recover funds paid to an apartment owner should be dismissed for lack of jurisdiction, as it did not involve a core bankruptcy matter, and a recovery, if any, would not benefit debtor’s bankruptcy estate.