Issue link: https://mbozikis.ufcontent.com/i/1422521
186 confirming the plan has become final, (2) whether deposits required by the plan have been distributed, (3) whether the property proposed by the plan to be transferred has been transferred, (4) whether the debtor or the successor of the debtor under the plan has assumed the business or the management of the property dealt with by the plan, (5) whether payments under the plan have commenced, and (6) whether all motions, contested matters, and adversary proceedings have been finally resolved. F ED. R. BANKR. P. 3022, Advisory Committee Note (1991). On motion of the debtor or another party in interest, a case may be reopened in the same court in which the case was closed in order to administer assets, to accord relief to the debtor or for other cause. 11 U.S.C. § 350(b); FED. R. BANKR. P. 5010. The Bankruptcy Code does not define "other cause," and thus the decision as to whether to reopen a bankruptcy case lies within the court's discretion. See In re Shondel, 950 F.2d 1301, 1304 (7th Cir. 1991) ("In exercising its discretion to reopen a case, 'the bankruptcy court should exercise its equitable powers with respect to substance and not technical considerations that will prevent substantial justice.'") (internal citation omitted). It should be noted that reopening the case does not provide substantive relief and is only a "ministerial or mechanical act which allows the court file to be retrieved." In re Suplinskas, 252 B.R. 293, 294-95 (Bankr. D. Conn. 2000). 2. Dismissal and Conversion to Chapter 7 A debtor has the absolute right to convert its Chapter 11 case to Chapter 7 unless it has ceased to be a debtor-in-possession, the case was originally commenced as an involuntary proceeding, or the case was converted to Chapter 11 other than at the debtor's request. 11 U.S.C. § 1112(a). Additionally, at the request of a party in interest, and after notice and a hearing, Section 1112(b) of

