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012147P.pdf   05/19/2003  GMAC  v.  Union Bank & Trust
   U.S. Court of Appeals Case No:  01-2147
   Eastern District of Arkansas   
   Civil Case - conversion. District court erred in determining 
   Bank had a Article 4 security interest in dishonored check 
   proceeds and the interest was superior to GMAC's Article 
   9 security interest. Bank did not have a security interest in 
   other deposit or proceeds and did not extend credit or other 
   value to customer. District court erred in relying on parol 
   evidence to find Waiver Agreement was not intended to 
   extended beyond termination of subordination agreement. 
   Judgment and award of attorneys fees to Bank are reversed.