- Financial Institutions
- Trusts, Estates, and Wealth Transfer
- Case Western Reserve University School of Law, J.D., 1992, summa cum laude, Order of the Coif
Case Western Reserve Law Review, Executive Notes Editor, 1991-1992
- Cornell University, B.S., 1985
Bar & Court Admissions
- U.S. Court of Appeals for the Sixth Circuit
- U.S. District Court for the Northern District of Ohio
- U.S. District Court for the Southern District of Ohio
- U.S. District Court for the Western District of Pennsylvania
- Admitted to practice law only in the states listed above.
- The Honorable Frank J. Battisti, U.S. District Court for the Northern District of Ohio, 1992-1993
As a business litigator and partner, Lisa helps clients resolve disputes involving complex litigation including fiduciary litigation, defense of legal malpractice claims, consumer class actions, and oil and gas drilling and operations disputes. In addition, Lisa has significant experience defending claims of breach of contract, mortgage fraud, lender liability, and employment discrimination. Lisa resolves her clients' disputes through motion practice and trials in state and federal courts throughout Ohio and across the country, as well as through negotiations.
Lisa’s experience handling disputes involving fiduciaries has led her to be the co-chair of the trust and estate litigation subgroup. As a leader in the trust and estate litigation subgroup, Lisa is at the cutting edge of trends in the field.
As part of the Vorys e Control team, Lisa counsels businesses on strategies for protecting their brands and reputations online and combating illegal online sales. In doing so, Lisa assists clients in developing legal claims against unauthorized online sellers, including enforcing trademarks through the Lanham Act and related claims.
Career highlights include:
- Defeating a consumer class action complaint brought under Ohio's Consumer Sales Practice Act and upholding that judgement on appeal
- Defending attorneys and law firm against claims of legal malpractice in the drafting of estate planning documents; achieving favorable settlement
- Winning a defense verdict defeating 13 claims of breach of fiduciary duty against a trustee of an irrevocable trust and then protecting that judgment on appeal; the eventual settlement of the matter resulted in Vorys’ client recovering $1 million from the plaintiffs
- Successfully litigating issues involving petition and ballot initiatives under Ohio law
- Oversight over a team of in excess of 30 lawyers handling hundreds of pieces of litigation in 28 states defending against lender liability claims.
- Providing guidance to the Secretary of State regarding the proper exercise of county and local petition power under the Ohio Constitution
- Obtaining successful settlements in a complex mortgage fraud case in state court involving 22 borrowers
- Winning a unanimous defense verdict in an age discrimination case brought under state law
Lisa is a member of the Ohio State Bar Association, the Ohio Women's Bar Association and the Cuyahoga Metropolitan Bar Association. In 2017, Lisa was selected to join the Estate Planning, Trust and Probate Law Section council of the OSBA.
Lisa regularly speaks and writes on her experience in several areas including trust and estate disputes, consumer finance, statewide regulation of oil and gas activity, depositions, trial practice and professionalism. A full list of her prior speaking engagements and articles she’s written can be found under “Events” and “Insights.”
Lisa is AV Preeminent® Peer Review Rated™ by Martindale-Hubbell.
Lisa received her J.D. summa cum laude from Case Western Reserve University School of Law where she was a member of the Order of the Coif and the executive notes editor of the Case Western Reserve Law Review. She received her B.S. from Cornell University.
Professional and Community Activities
- Cleveland Metropolitan Bar Association Certified Grievance Committee, member, 2018 to present
- Ohio State Bar Association, Estate Planning, Trust and Probate Law Section council, 2017 to present
- Cornell Alumni Admissions Ambassador Network, Member, 2011 to present
- Center for Families and Children, Board of Directors, 2008 to present; Vice Chair of the Board, 2019 to present; Chair, Program and Operations Committee, 2013 to 2018; Co-Chair, Quality, Risk and Program Committee, 2018 to present
- Circle Health, Board of Directors, 2017 to present; Co-Chair Quality, Risk and Program Committee, 2018 to present
- El Barrio, Board of Directors, 2011 to present
- Ohio Women’s Bar Association, Eighth District Trustee, 1999 to 2002; Program and Projects Committee Co-Chair, 2003-2004; Recipient of the OWBA's President's Choice Award 2002
- Federal Bar Association, Board of Directors, 2011
Honors & Awards
- Martindale-Hubbell AV Peer Review Rated
- Cleveland's Top Lawyers, 2012
- Ohio Super Lawyers, Business Litigation, 2010-2011
- YWCA Business Women of Professional Excellence Award, 2008
- Eighth District Judicial Conference, Life Member
- 7/8/2019The rapid growth of Amazon and other online marketplaces has created a new ecosystem in which brands struggle to control their product sales. Brands now find their products sold by anonymous online sellers and face new challenges on an unprecedented scale. The eControl360 Summit is a first-of-its-kind event that will bring together thought leaders in each of the disciplines necessary to tackle these challenges and allow brands to retake control of their online sales.
- 11/8/2019Vorys Attorneys Lisa Babish Forbes, Kari Coniglio and Carrie Brosius presented at the Commercial Dockets Seminar put on by the Supreme Court of Ohio Judicial College on November 8, 2019.
- 11/6/2019The rapid growth of Amazon and other online marketplaces has created a new ecosystem in which brands struggle to control their product sales. Brands now find their products sold by anonymous online sellers and face new challenges on an unprecedented scale. The eControl360 Summit was a first-of-its-kind event that brought together thought leaders in each of the disciplines necessary to tackle these challenges and allow brands to retake control of their online sales.
- 10/15/2019Vorys Attorneys Lisa Forbes and Beth Weinewuth spoke at the Fiduciary and Risk Management Association’s (FIRMA) Current Risk Issues Seminar on October 15, 2019.
- 9/23/2019Vorys Partner Lisa Forbes presented at the 14th Annual Estate Planning Seminar sponsored by Boy Scouts of America, Lake Erie Council on September 23, 2019.
- 9/13/2019Vorys Attorneys Lisa Forbes and Beth Weinewuth spoke at the Marvin R. Pliskin Advanced and Estate Planning Seminar co-sponsored by the Ohio State Bar Association on September 13, 2019.
- 10/23/2018Vorys hosted a webinar series highlighting important topics in the consumer finance industry on October 23, 2018.
- 10/19/2018Vorys Partners Lisa Forbes and Phil Downey spoke to the Akron Bar Association's Estate Planning, Probate and Elder Law Section on October 19, 2018. They presented on digital age considerations for probate practitioners.
- 8/23/2018Three Vorys partners presented at the 2018 Ohio State Bar Association Convention/Legal Forum on August 23-24, 2018.
- 4/26/2018Vorys Partners Lisa Babish Forbes and Phil Downey presented at the Ohio Association of Magistrates 2018 Spring Conference on April 26, 2018.
- 4/10/2018Vorys is proud to host a webinar series highlighting important topics in the consumer finance industry. Previous webinar dates included March 15, April 10 and May 8, 2018.
- 3/20/2018Vorys Partner Lisa Forbes was a speaker at the Cleveland Metropolitan Bar Association on March 20, 2018.
- 12/7/2017Vorys attorneys Colleen Laux J.B. Lind, Beth Weinewuth, and Lisa Babish Forbes presented at Butler County Bar Association’s trust and estate CLE presentation on December 7, 2017.
- 9/22/2017Vorys Partner Lisa Forbes was a speaker at the Akron Bar Association’s Trust and Estates Committee Meeting on September 22, 2017. Her presentation was titled “A Tangled Web: Conflicts of Interest in Trust Administration.”
- 7/13/2017Vorys Partners Lisa Forbes, Emily Pan and Beth Weinewuth were speakers at the 2017 Representing Estate and Trust Beneficiaries and Fiduciaries conference hosted by the American Law Institute on July 13, 2017.
- 6/20/2017Vorys partners Beth Weinewuth, Lisa Forbes and Emily Pan presented at the Ohio State Bar Association Basics of Estate Administration Seminar on June 20, 2017.
- 4/24/2017Vorys Partners Lisa Babish Forbes and Michael Schwartz were speaker at the 2017 Fifth Third Trust Officer & Portfolio Manager Conference on April 24-25, 2017.
- 4/21/2017Vorys Partners Phil Downey and Lisa Forbes spoke on "Conflicts of Interest: Trust and Estate Administration" hosted by the Akron Bar Association on April 21, 2017.
- 1/25/2017Vorys Partners Lisa Babish Forbes and Marcel Duhamel were speakers at the CMBA Litigation Section Lunch and CLE Presentation hosted by the Cleveland Metropolitan Bar Association on January 25, 2017.
- 10/28/2016Vorys Partners Phil Downey and Lisa Babish Forbes were speakers at the Tuscarawas County Bar Association monthly meeting on October 28, 2016.
- 9/13/2016Vorys Partner Lisa Babish Forbes was a speaker at the OSBA Litigation Basics CLE on September 13, 2016.
- 7/7/2016Vorys attorneys Lisa Forbes, Emily Pan and Beth Weinewuth were speakers at the ALI-CLE Representing Estate and Trust Beneficiaries and Fiduciaries on July 7, 2016.
- 6/22/2016Several Vorys attorneys were speakers at the 2016 Consumer Financial Services Summit on June 22, 2016 in Columbus, Ohio.
- 6/21/2016Vorys attorneys Vic Ferguson and Lisa Forbes were speakers at the Cleveland Metropolitan Bar Association’s Estate Planning, Probate & Trust Law Section’s Hot Topics for Estate Planners program on June 21, 2016.
- 6/9/2016Vorys attorney Lisa Forbes and Emily was a speaker at the Henry County Bar Association on June 9, 2016.
- 3/18/2016Vorys Partner Lisa Forbes was a speaker at the Akron Bar Association’s Trust and Estates Committee Meeting on March 18, 2016.
- 11/20/2015Vorys attorneys Dan Clark, Lisa Forbes and Greg Russell were speakers at the Oil and Gas Update hosted by the Ohio State Bar Association Natural Resources Law Committee on November 20, 2015.
- 10/28/2015Vorys presented a Consumer Financial Services Summit on October 28, 2015 in Cleveland, Ohio.
- 9/11/2015Vorys Partner Lisa Forbes was a speaker at the Litigation Basics Seminar hosted by the Ohio State Bar Association on September 11, 2015.
- 3/25/2015Vorys attorneys Lisa Forbes and Beth Weinewuth presented to the Catholic Foundation’s Professional Advisors Group on March 25, 2015.
- 12/5/2014Vorys attorneys Lisa Forbes and Phil Downey were speakers at the Tuscarawas County Bar Association CLE on December 5, 2014.
- 10/28/2014Vorys partner Lisa Forbes was a speaker at the CFPB and Beyond: Consumer Finance Update hosted by the Ohio State Bar Association on October 28, 2014.
- 5/4/2014Vorys partner Lisa Babish Forbes presented at the MBA Legal Issues and Regulatory Compliance Conference on May 4, 2014.
- 3/14/2014Vorys attorneys Lisa Forbes and Beth Weinewuth were speakers at 2014 Annual Estate Planning, Trust, and Probate Law Institute hosted by the Dayton Bar Association on March 14, 2014. Their presentation is titled Armor for the Trustee: Limitation of Liability Provisions and Releases of the Trustee.
- 7/18/2019Supreme Court Holds State May Not Impose Tax on Trust Income Based Solely on Residency of In-State BeneficiaryIn North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust, Case No. 18-457, 588 U.S. __ (2019), the Supreme Court held that states may not impose a tax on trust income based solely on the residency of an in-state beneficiary.
- 2/28/2019Lisa Babish Forbes, a partner in the Vorys Cleveland office, authored an article in the January/February 2019 issue of the Probate Law Journal of Ohio titled, “Online Notaries and Beyond: An Update on Ohio’s Notary Public Modernization Act.”
- 2/13/2019Client Alert: Embassy Healthcare v. Bell: Supreme Court of Ohio Decision Provides Greater Certainty for a Surviving Spouse on Decedent Spouse’s Medical DebtIs a surviving spouse responsible for her deceased spouse’s medical bills if the creditor did not properly submit a claim against his estate?
- 10/31/2018Lisa Babish Forbes, a partner in the litigation group in the Vorys Cleveland office, authored an article in the September/October 2018 issue of the Probate Law Journal of Ohio titled, "Online Notaries Are Coming (And Why You Should Care)."
- 1/22/2018Client Alert: End of Year Roundup: Ohio Courts Provide Important Practice Pointers for Trust and Estate Professionals and PractitionersOhio courts were busy in the month of December, issuing a number of opinions related to trust and estate planning and administration.
- 10/3/2017Case Note: A. Bogar v. Mark Baker, et al: When Language Is Ambiguous, Don’t Forget the Testator’s Intent“Together with all contents of said real estate.” It sounds straightforward. But what happens when the “real estate” is a farm and the “contents” in question include trucks and farm machinery?
- 8/24/2017Client Alert: Dueck. v. The Clifton Club Company, et al. - Ohio’s Eighth District Court of Appeals Recognizes Fiduciary Exception to the Attorney-Client PrivilegeThe Eighth District Court of Appeals surprised many Ohio practitioners this month by applying a fiduciary exception to the attorney-client privilege in Dueck v. The Clifton Club Company.
- 8/7/2017Case Note: In re Estate of Kiefer & Poston v. Shelby-Love: Two New Court of Appeals Decisions Reaffirm the High Bar to Establish Undue InfluenceThe Second and Eighth District Courts of Appeals demonstrate how difficult it is to establish undue influence.
- 7/20/2017A recent decision by the Court of Appeals for the Ninth Appellate District illustrates Ohio courts’ reluctance in removing fiduciaries.
- 6/30/2017Client Alert: Sigler v. Burk: Ohio Court of Appeals Applies the Presumption of Undue Influence When Assets Left to a FiduciaryThe Court of Appeals for the Third Appellate District recognized the strength of the presumption of undue influence in a will contest case, overturning an award of summary judgment because of the presumption. Sigler v. Burk, 2017-Ohio-5486, decided on June 26, 2017, demonstrates why, in drafting a will or trust, you should think carefully about any fiduciary role (or roles) assumed by the beneficiaries of the will or trust.
- 6/1/2017Client Alert: Young v. Bellamy: Ohio Court of Appeals Affirms Summary Judgment in Will Contest, Confirms High Bar to Overturn a Will on Undue Influence or Lack of Testamentary Capacity GroundsContestants of an Ohio will must overcome a very high threshold to establish that a decedent was unduly influenced or lacked testamentary capacity. Young v. Bellamy, decided on May 24, 2017, provides a new example of just how difficult it is to overturn a will.
- Spring 2017Wilson v. Lawrence: Ohio Supreme Court Upholds Strict Interpretation of Statute Governing Presentment of Claims Against Estates; Rejects Argument of Substantial ComplianceCreditors of Ohio estates have little room for error under a decision handed down by the Supreme Court of Ohio on April 19, 2017.
- 4/28/2017Client Alert: McHenry v. McHenry: Ohio Fifth Appellate District Rejects Rule of Proportionality for Attorney Fee Awards in Trust Cases; Upholds Award of Appellate Attorneys’ FeesOn April 26, 2017, the Ohio Fifth Appellate District rejected a rule of proportionality in awarding attorneys’ fees in trust litigation.
- 4/21/2017Client Alert: Wilson v. Lawrence: Ohio Supreme Court Upholds Strict Interpretation of Statute Governing Presentment of Claims Against Estates; Rejects Argument of Substantial ComplianceCreditors of Ohio estates have little room for error under a decision handed down by the Supreme Court of Ohio on April 19, 2017.
- 3/14/2017Client Alert: Zook v. JPMorgan Chase Bank: Tenth District Rules that Trust Beneficiary Carries the Burden of Proving that a Trustee Release is InvalidLast week, the Tenth District Court of Appeals upheld summary judgment in favor of an institutional trustee where trust beneficiaries sued the trustee—after executing a release of the trustee for actions taken in administration of the trust— for negligence and breach of fiduciary duty.
- 12/19/2016Client Alert: Ohio Senate Bill 232: Divorce Terminates Transfer-On-Death Deeds to Ex-Spouses Automatically and Inheritance Rights of the Pre-Gestated and Pre-Conceived are LimitedLast week, Governor Kasich signed into law Senate Bill 232, which makes changes to Ohio’s statutes on intestacy, wills, and trusts.
- 11/1/2016Vorys Partners Lisa Babish Forbes and Emily Pan co-authored an article titled "Fixing Broken Trusts by Court Modification - From the Trustee's Perspective" for the Probate Law Journal of Ohio (Volume 27, Issue 2).
- 7/1/2016Vorys Partners Lisa Babish Forbes and Emily Pan co-authored an article titled "Fixing Broken Trusts by Agreement - From the Trustee's Perspective," for the Probate Law Journal of Ohio (Volume 26, Issue 6).
- 6/6/2016Client Alert: Gehrke v. Senkiw: Ohio Appellate Court Decision May Shorten Time to Contest the Validity of Revocable TrustsThe Second District Court of Appeals has issued an opinion in Gehrke v. Senkiw, 2d Dist. Montgomery No. 26829, 2016-Ohio-2657, which held that the validity of a revocable trust that the settlor’s will incorporates by reference cannot be challenged without also challenging the settlor’s will.
- 6/2016Lisa Babish Forbes, a partner in the litigation group in the Vorys Cleveland office, authored an article for the June 2016 edition of the Cleveland Metropolitan Bar Journal titled “No Contest Clauses in Ohio.”
- 5/26/2016Faced with a petition drive to put a minimum wage proposal on the November ballot, Cleveland City Council must now consider an ordinance that would mandate a $15 per hour minimum wage for those employees working within Cleveland’s geographic boundaries.
- 5/25/2016The first wave of attacks on the Consumer Financial Protection Bureau’s (CFPB) recently proposed rules prohibiting class action waivers in pre-dispute arbitration agreements occurred during the House Financial Institutions and Consumer Credit Subcommittee hearing entitled “Examining the CFPB’s Proposed Rulemaking on Arbitration.
- 5/25/2016Financial Services Alert: Regulations Prohibiting Class Action Waivers Published in Federal RegisterOn May 24, 2016 the Consumer Financial Protection Bureau’s (CFPB) proposed arbitration rule was published in the Federal Register.
- 5/16/2016Financial Services Alert: Narrow Win For Spokeo at The U.S. Supreme Court: Plaintiffs Must Demonstrate Concrete Harm Even For Statutory ViolationsIn a highly-anticipated opinion, this morning the U.S. Supreme Court overturned the Ninth Circuit Court of Appeals’ decision in Spokeo, Inc. v. Robins.
- 5/6/2016Financial Services Alert: CFPB Invites Comment on Newly Proposed Regulations Banning Class Action WaiversThe Consumer Financial Protection Bureau (CFPB) yesterday released a widely anticipated proposed rule that would: (1) prohibit class action waivers in pre-dispute arbitration agreements, and (2) require a provider to submit records from individual arbitrations to the CFPB.
- 3/4/2016Oil and Gas Alert: Local Initiative Power is Limited by the Home Rule Amendment: City of Broadview Heights Community Bill of Rights is InvalidThe Eighth District Court of Appeals recently struck down the Broadview Heights Community Bill of Rights as an invalid exercise of the home rule authority. The Community Bill of Rights, also known as Article XV of the City Charter, banned new oil and gas drilling and limited operation of current wells in the city. It also made it illegal to challenge Article XV as preempted by state law.
- 11/6/2015During Monday’s oral argument in Spokeo, Inc. v. Robins, No. 13-1339, the Supreme Court appeared sharply divided on the issue of whether a plaintiff has standing to sue for a technical violation of a federal consumer law even when there is no indication that the plaintiff has actually been harmed by the violation.
- 10/26/2015Lisa Babish Forbes and Aaron Williams, attorneys in the Vorys Cleveland office, co-authored “Can Localities Use Ballot Power To Ban Oil And Gas Drilling?” for Appellate Law360.
- 8/18/2015Oil and Gas Alert: Ohio Secretary of State Refuses to Place Proposed County Charter Petitions Banning Oil and Gas Activities on the November BallotOn Thursday, August 13, Secretary of State John Husted issued a decision finding that the proposed charter petitions for Athens, Fulton and Medina counties are invalid. The secretary’s decision tracked analysis provided by Vorys’ attorneys Jonathan Airey, Gregory Russell, Lisa Babish Forbes and Aaron Williams in an amicus brief submitted on behalf of the Ohio Oil and Gas Association and the Ohio Gas Association.
- May/June 2015Vorys attorneys Daniel Buckley, Lisa Babish Forbes and Elizabeth Weinewuth authored an article for the Probate Law Journal of Ohio titled “Newcomer V. National City Bank Appeal Concludes, Affirms Important Guidance for Ohio Trustees.”
- 3/16/2015The Consumer Financial Protection Bureau (CFPB) released a study on March 10, 2015 that concludes that pre-dispute arbitration agreements restrict a consumers’ relief. This study is the latest step in the CFPB’s analysis of lenders’ arbitration practices and is widely regarded as a precursor to new regulations.
- 1/20/2015Client Alert: U.S. Supreme Court Holds That Borrowers Need Only Give Notice of Intent to Rescind Under TILA within Three Years of ClosingOn January 13, 2015, the United States Supreme Court ruled in favor of homeowners seeking to rescind their loans and mortgages with written notice to lenders within three years of completion of a real estate transaction, where lenders allegedly failed to comply with the federal Truth in Lending Act (TILA). Based on this decision in Jesinoski v. Countrywide Home Loans, Inc., it is not necessary that a homeowner actually file a court action within those three years.
- 12/1/2014Lisa Babish Forbes, a partner in the Vorys Cleveland office and a member of the litigation group, authored an article for the Cleveland Metropolitan Bar Journal titled “Exculpatory Clauses: They May Not Mean What They Say.”
- 8/27/2014On August 22, 2014, the Sixth District Court of Appeals affirmed on all counts a Williams County probate court’s September 2012 decision in favor of PNC Bank, National Association against successor trustee and beneficiaries’ various breach-of-fiduciary-duty claims. The decision in Newcomer v. National City Bank, (2014-Ohio-3619; 2007 Ohio App. LEXIS 6365 (Ohio App. 6th Dist.)) provides critical guidance for Ohio trustees on four key points of law.
- 7/9/2014Client Alert: Ohio Appellate Court Interprets OTC and UPOAA; Allows New Claim for Treble Damages by Vested BeneficiariesOn July 3, the Second District Court of Appeals issued an opinion in Cartwright v. Batner, 2014-Ohio-2995 (Ohio App. 2 Dist.), which interprets both the Ohio Trust Code and Ohio’s Uniform Power of Attorney Act, recognizes a new claim for treble damages by vested beneficiaries, and provides guidance on a variety of issues important to estate planners, fiduciaries, beneficiaries and those who represent them.
- 6/19/2014Lisa Forbes, a partner in the Vorys Cleveland office and a member of the litigation group, authored an article titled "Avoiding Liability: Considerations and Guidelines for Not-for-Profit Directors and Officers" for the Cleveland Metropolitan Bar Association.
- 1/6/2014Lisa Babish Forbes, a partner in the Cleveland office and Elizabeth E.W. Weinewuth, an associate in the Cincinnati office, authored this article on Fiduciaries Under Fire for the Winter 2014 issue of The Bankers' Statement.
- 1/6/2014Lisa Babish Forbes, a partner in the Cleveland office and Elizabeth Davis Conway, an associate in the Cleveland office, authored this article on the Ohio Uniform Fiduciaries Act for the Winter 2014 issue of The Bankers' Statement.
- 6/19/2013The United States Court of Appeals for the Sixth Circuit recently clarified the operation of the Ohio Uniform Fiduciaries Act (UFA) when it affirmed the dismissal of a complaint alleging multiple claims against a banking client. The Complaint arose out of the misappropriation of funds by the authorized fiduciary of trust and estate accounts held at the bank.
- 5/20/2013Lisa Babish Forbes, a Cleveland partner, and Elizabeth E.W. Weinewuth, a Cincinnati associate, published this article in the Spring 2013 issue of The Bankers' Statement.
- March/April 2013Vorys attorneys Daniel Buckley, Lisa Babish Forbes, Elizabeth Weinewuth and Elizabeth Davis Conway authored an article for the Probate Law Journal of Ohio titled "Important Guidance for Ohio Trustees: Newcomber V. National City Bank."
- 1/22/2013A recent trial victory on behalf of a major banking client clarifies three key points of law in Ohio fiduciary litigation. In June 2012, a Vorys trial team led by Daniel J. Buckley and Lisa Babish Forbes defended a trustee in a five-day bench trial against numerous breach of fiduciary duty claims brought by successor trustees and beneficiaries.
- 6/5/2012This Independence Day, businesses in Ohio will have one more tool to attempt to resolve claims brought under the Ohio Consumer Sales Practices Act (CSPA). Effective July 3, 2012, companies sued under Ohio's CSPA can follow a statutory process to attempt to settle a claim at the beginning of a case.