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The Barton Doctrine is not absolute, and there are exceptions that must be considered. The first is not necessarily an exception, but a practical effect of the doctrine, and would seem self-evident. It does not prevent a creditor or other litigant from bringing the action in the bankruptcy court. Such actions are permitted inasmuch as the claim against the trustee would remain within the jurisdiction of the appointing court. Next, in the event that a trustee is actually operating an enterprise, rather than simply administering and liquidating

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