Proof of value is a bankruptcy lawyer’s stock in trade. It is the rare debtor, creditor, or trustee who does not eventually need to prove the value of a piece of collateral, or a business, or an intangible right. One of the most powerful tools in a lawyer’s valuation arsenal is the report of a professional “valuer”—an appraisal report, a valuation report, a broker’s price opinion, or a comparative market analysis. But such a report doesn’t do a litigant much good if the litigant can’t get that report admitted into evidence. And that is where the evidence problems come in.
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