PHILADELPHIA - A panel of the Third Circuit U.S. Court of Appeal on Feb. 19 ruled that a bankruptcy court ruled properly when it approved a settlement in a company's Chapter 11 bankruptcy because the litigation to dispute various claims would have been "complex," and collection of an eventual judgment would have been difficult (Ross J. Mangano v. John C. Warriner, et al. $(In Re: ID Liquidation One LLC$), No. 13-3386, Chapter 11, 3rd Cir.; 2014 U.S. App. LEXIS 2971).