Zhu Zhai Holdings Limited v. Ivankovich

Plaintiffs, in seeking to collect on a default judgment against the defendant, issued citations on various entities to discover the defendant’s assets. The district court appointed a special master to sort through the facts and post-judgment disputes and the special master concluded that certain assets, which were once held in an escrow account as security for loans, belonged to the defendant and not to one of the limited liability companies that laid claim to the same assets. The district court adopted the special master’s findings and defendant appealed. The Seventh Circuit affirmed, finding no error. (BRENNAN and TAIBLESON, concurring)