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13 The "interest of justice" component of § 1412 is a broad and flexible standard which must be applied on a case-by-case basis. It contemplates a consideration of whether transferring venue would promote the efficient administration of the bankruptcy estate, judicial economy, timeliness, and fairness . . . . Gulf States Exploration Co. v. Manville Forest Prod. Corp. (In re Manville Forest Prod. Corp.), 896 F.2d 1384, 1391 (2d Cir. 1990). Courts have applied the flexible standard embodied in Section 1412 in various ways, some using specified factors and some without applying a factor test. See In re Patriot Coal Corp., 482 B.R. at 739 (listing cases). Additionally, courts may consider the manner in which a party complied with the venue rules in considering the "interest of justice" component of Section 1412. See id. The procedure governing the transfer of cases is set forth in Bankruptcy Rule 1014(a). C. Abstention Abstention refers generally to the doctrine whereby a Federal court having jurisdiction declines to exercise such jurisdiction. In certain instances, abstention is permissive, whereas in other situations it is mandatory. As it relates to bankruptcy matters other than Chapter 15 cases ancillary to foreign proceedings, district courts are permitted to abstain from hearing a proceeding arising under title 11 or arising in or related to a case under title 11 "in the interest of justice, or in the interest of comity with State courts or respect for State law." 28 U.S.C. § 1334(c)(1). District courts must abstain from hearing civil proceedings related to a case under title 11 where such related proceeding could not have been commenced in Federal court but for the bankruptcy, such proceeding is the subject of a State court action and the action can be timely adjudicated in the State court. 28 U.S.C. § 1334(c)(2). These provisions apply equally to the bankruptcy courts. Nickless

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