"The appointment of the receiver removed the wrongdoer from the scene. The corporations were no more Douglas's evil zombies. Freed from his spell they became entitled to the return of the moneys-for the benefit not of Douglas but of innocent investors-that Douglas had made the corporations divert to unauthorized purposes."
Posner, J., in Scholes v. Lehmann, 56 F.3d 750 (7th Cir. 1995).
Now, how can I work an "evil zombies" reference into the brief I've been working on? It might not be a problem.