BAPCPA Outline: Part VI, Sections A-I: Chapter 7 Liquidations -- Means Testing: Is Its Bark Worse Than Its Bite?
One idiomatic expression that translates well in any language is "his bark is worse than his bite" (which I suppose is a testament to the universality of both dogs and common sense). This expression comes to mind when considering BAPCPA's new bankruptcy "means test." This eighth installment of the BAPCPA Consumer Bankruptcy Outline for cases decided between 6/1/05 and 5/31/06 addresses issues arising in the chapter 7 context, including BAPCPA's barking dog, the "means test."
In signing BAPCPA, President Bush issued a statement in which the "means test" was cited as one of BAPCPA's prime movers. The President said:
In recent years, too many people have abused the bankruptcy laws. They’ve walked away from debts even when they had the ability to repay them. This has made credit less affordable and less accessible, especially for low-income workers who already face financial obstacles. The bill I sign today helps address this problem.
Well, it turns out there's more bark than bite to the means test, and that the many modifications to the means test over the nine years it took to get BAPCPA enacted diluted it to such a great extent that only a handful of debtors will ever flunk it. Even before BAPCPA became effective, however, Chicago's Judge Eugene Wedoff was among the first to have predicted as much. He wrote:
Perhaps the best-known and most discussed feature of [BAPCPA] is its means test. Indeed, means testing has been a central feature of the bankruptcy reform legislation that Congress has considered in every term since 1997. As reflected in the comments of Senator Grassley set out above, means testing has a simple purpose: to measure the ability of Chapter 7 debtors to repay debt and then, if they have sufficient debt-paying ability, to make them repay at least some of their debt--likely through Chapter 13--in order to receive a bankruptcy discharge. This Article suggests, however, that BAPCPA's means test is not simple and is not likely to achieve what its sponsors intended. See Hon. Eugene R. Wedoff, Means Testing in the New § 707(b), 79 Am. Bankr. L. J. 231 (2005).
Still, even if the new law's bark is worse than its bite, the new law has taken a significant bite out of bankruptcy filings by consumers, at least in the short term. As reported here, with consumer bankruptcy filings down to about 1/3 of last year's levels, Sam Gerdano (the American Bankruptcy Institute's executive director, and former chief legal counsel to BAPCPA's sponsor, Senator Charles Grassley) remarked, "[t]he big story is, Congress wanted to suppress the number of filings, and they have succeeded mightily."
In the past year, cases interpreting the means test in the chapter 7 context have been few and far between, with no reported cases addressing the nuances of the means test head on (at least in the chapter 7 context). Still, as Judge Wedoff's article makes clear, calculating whether someone passes or flunks the means test is one of BAPCPA's most mystifyingly mind-numbing tasks, and fundamental misunderstandings still abound among experienced practitioners.
I think the most interesting of all cases cited below is that of Judge Leslie J. Tchaikovsky in In re Pak, 343 B.R. 239 (Bankr. N.D. Cal. 2006) (see Section D, below), where the court held that there is no safe harbor for debtors who flunk the means test on the petition date such as would prevent the court from exercising its own discretion and dismissing the case under Code section 707(b)(3)(B)'s "totality of circumstances" test. Most notably, Judge Tchaikovsky weighed in on the raging debate between "respected academics" Marianne B. Culhane and Michaela M. White on the one hand, and Judge Wedoff, "also highly respected for his expertise on BAPCPA," on the other. In the end, Judge Tchaikovsky rejected Culhane and White's views, reflected in this article (entitled Catching Can-Pay Debtors: Is the Means Test the Only Way?, 13 Am. Bankr. Inst. L. Rev. 665 (2005)), which they wrote for purposes of rebutting certain of Judge Wedoff's views in the article cited above (which views were adopted by Judge Tchaikovsky). In conclusion, Judge Tchaikovsky held, "while BAPCPA did severely limit judicial discretion..., [it] has not been entirely eliminated."
Thanks for reading.
VI. Chapter 7
A. Means Testing: A Non-Issue?
1. First case interpreting "means test" standards under § 707(b)(2)(A) and its application in the chapter 13 plan confirmation context for determining the debtor's "projected disposable income." In re Hardacre, 338 B.R. 718 (Bankr. N.D. Tex. 2006) (Nelms, J.). For other cases, see Section on Chapter 13, infra, and discussion of "projected disposable income" test. Court holds:
a. Any determination of the debtor's "projected disposable income," such as when debtor is required to devote to payments under plan, must be based on debtor's anticipated income over term of plan;
b. In applying "means test" for "projected disposable income," the debtor could not double-count housing and transportation expenses;
c. In determining "projected disposable income," the debtor may deduct a sum equal either to standard allowances or actual housing and transportation expenses, whichever is greater;
d. Debtor could not deduct standard expense for vehicle owned free and clear; and
e. Section 707(b)(2)(A)(ii)(I) precludes debtor from claiming expenses under both the Local Standards and the debtor’s actual average monthly expense, but the debtor can claim the greater of the two. In re Hardacre, 338 B.R. 718 (Bankr. N.D. Tex. 2006) (Nelms, J.)
2. Debtors failed to rebut presumption of abuse under means test because circumstances did not present special circumstances such as those identified by the statute (e.g., serious medical condition or call to active duty). Here, the debtors checked the box on the means test calculation form indicating the presumption of abuse. The US Trustee even withdrew the motion to dismiss. The US Trustee, however, did object to the debtors' inclusion of future payments on secured claims on two vehicles which were surrendered after the bankruptcy filing. "The potential payback of zero percent to unsecured creditors in a Chapter 13 is not a special circumstance contemplated under § 707(b)(2)(B)." In re Johns, 342 B.R. 626 (Bankr. E.D. Okl. 2006) (Cornish, J.).
B. Challenges to Discharge
1. Finding that chapter 7 debtor exhibited "careless and reckless approach" to duty of disclosure in sworn filings did not establish knowing misconduct. Bankruptcy court did not make requisite finding that debtor acted "knowingly" in failing to disclose rental income and proceeds from sale of horse on his statement of financial affairs, thus precluding denial of discharge on grounds that debtor knowingly and fraudulently made false oath or account in course of bankruptcy proceedings. Roberts v. Erhard (In re Roberts), 331 B.R. 876 (Bankr. 9th Cir. 2005) (Bufford, J.).
2. Discharge denied of debtors whose explanation for absence of financial records to document what happened to hundreds of thousands of dollars in funds acquired through three different business was that records had been lost when debtors were twice evicted for nonpayment of rent. This explanation would not prevent denial of debtors' discharge under "recordkeeping" discharge exception. Standard of proof in proceeding to deny debtor a discharge is proof by preponderance of evidence. Substantially accurate and complete records of debtor's financial affairs are prerequisite to debtor's discharge in bankruptcy. Bodenstein v. Wasserman (In re Wasserman), 332 B.R. 325 (Bankr. N.D. Ill. 2005) (Schmetterer, J.).
3. To bar discharge, chapter 7 debtor's false oath must be "material" in that its subject matter must concern discovery of assets or existence and disposition of estate property. Bankruptcy Court's finding that failure to list diamond ring on original schedules is knowing falsehood that warrants denial of discharge was clearly erroneous and would be reversed. Noncontradictory reasons given by debtor for omission were consistent with innocent intent. Further, ring had only trivial value. Ellsworth v. Bauder (In re Bauder), 333 B.R. 828 (Bankr. 8th Cir. 2005) (Venters, J.).
4. Discharge denied due to uncorrected material mistakes in schedules and statement of affairs, including various business and partnership interests, which the Court inferred were knowingly and fraudulently made because of the failure to correct. Discharge denied under Section 727(a)(4). Discharge also denied under Section 727(a)6) for failure to comply with Court order requiring production of financial documents for trustee's case administration. In re Foster, 335 B.R. 709 (Bankr. W.D. Mo. 2006) (Dow, J.).
5. Court denies American Express's challenge to discharge of low income creditor who ran up credit cards within months of filing. Denial based on creditor's inability to admit electronic records on evidentiary grounds because of lack of requisite foundation to admission of these records (even after given opportunity to supplement record). Court states that where there is no paper trail, the authentication process requires that the records custodian be certain that the printed documents are what they purport to be. Court states: "[T]he focus is not on the creation of the record, but on the circumstances of the preservation of the record during the time it is in the file so as to assure that the document being proferred is the same as the document that originally was created." The custodian here failed to supply the requisite authentication because it merely declared its familiarity with the company's computers, software and record keeping systems, which alone was insufficient to supply the requisite authentication. Absent the business records, the creditor could not prove that the claim should be excepted from discharge. American Express Travel Related Servs. Co., Inc. v. Vinhnee (In re Vinhnee), 336 B.R. 437 (Bankr. 9th Cir. 2005).
6. Debtors with sufficient disposable income to fund a three-year chapter 13 plan that fully repaid their creditors were not entitled to a chapter 7 discharge. In re Delarosa (Bankr. N.D. Tex. 2005) (Felsenthal, J.) (no WL citation available).
7. Court denies trustee's request to permit debtor's parents to settle Section 727 discharge litigation by making a cash payment to the trustee. Court states: "A compromise in which a party agrees, in exchange for the payment of money, to dismiss an action to deny a debtor's discharge is tantamount to allowing a debtor to purchase a discharge…. Allowing the dismissal of an action to deny a debtor's discharge to be conditional upon Debtor's payment of money encourages the use of an objection to discharge as a weapon to induce the debtor to accede to demands which may be otherwise excessive." In re Delco (Bankr. N.D. Ga. 2005) (Murphy, J.) (no WL citation available).
8. Chapter 7 debtor's fraudulent transfers of money to relatives, former wives, and girlfriend justified denial of discharge. While property transferred belonged to debtor's plumbing business, debtor was the business's sole officer, director, and corporate shareholder. Thus, the property was effectively property of the estate. Further, debtor intended to hinder, delay, or defraud creditors given relationship to recipients of payments and lack of documentary evidence that consideration was received in exchange. Also, the debtor's business was struggling, the debtor personally guaranteed company debt, and a creditor hounding the debtor for payment. In re Lort, 343 B.R. 302 (Bankr. M.D. Fla. 2006) (Proctor, J.).
9. Debtor's failure to report or turn over proceeds received postpetition from payment of undisclosed promissory note held on petition date from undisclosed sale was "knowing" and "fraudulent," thus warranting revocation of discharge. Even if debtor's initial failure to disclose was based on good faith belief that assets were worthless since parties were unable to obtain requisite development permits, debtor should have known when advised that promissory note would be paid that he was wrong in his belief, yet he failed to remedy earlier nondisclosures or to report or turn over the note's proceeds. Grossman v. Foster (In re Foster), -- B.R. -- (Bankr. D. Mass. 5/24/06) (Somma, J.).
C. Conversion to Chapter 13
1. Debtor did not act with improper purpose or abuse motive in seeking to convert to chapter 13 in order to regain control over litigation of her equitable distribution claim in pending divorce action and thereby preclude chapter 7 trustee's proposed settlement of her divorce proceeding. Conversion is warranted also given that debtor adequately disclosed equitable distribution claim and husband's disputed claim against chapter 7 estate and cooperated with trustee's investigation of claim. Debtor believed claim worth $1,000,000, which would result in full payment to creditors. Also, debtor had obtained employment providing funding source for chapter 13 plan and had made three timely payments under her plan. In re Porreco, 333 B.R. 310 (Bankr. W.D. Pa. 2005) (Bentz, J.).
2. Sixth Circuit notes split of authority on whether Section 706 confers absolute right to convert from chapter 7 to chapter 13 where the case had not been previously converted. Court holds that a debtor’s right to convert from chapter 7 to chapter 13 is subject to the bad-faith exception. The court finds support in prior ruling that courts may dismiss a chapter 13 petition that is not filed in good faith. Also, court notes that BAP found that that the motion to convert was filed to avoid a determination that the debtor was not entitled to a discharge and not by a desire to repay its creditors. Thus, the motion to convert was an improper attempt to manipulate the system and the Code's requirements. Court further rejects debtor’s contention that §706 mandates an absolute right to convert “regardless of circumstances.” Court further notes that if Congress intended to divest bankruptcy court of discretion, it would have used the mandatory phrase "shall be able to convert," as found in 11 U.S.C. §1307(b). Copper v. Copper (In re Copper), 426 F.3d 810 (6th Cir. 2005) (Norris, J.).
3. Following Copper, Court holds that Section 706(a), which authorizes a chapter 7 debtor to convert to another chapter if it's eligible for relief under that chapter and case has not previously been converted does not confer absolute right to convert if these two conditions are met. Bankruptcy court may deny motion to convert where court determines that debtor engaged in bad faith conduct. [NB: The US Supreme Court has granted a petition for certiorari in this case, and will hear it in the 2006-07 term.] In re Marrama, 430 F.3d 474 (1st Cir. 2005) (Cyr, J.).
4. Section 706(a) precludes debtors from converting cases from chapter 7 to chapter 13 if case was previously converted to chapter 7. In re Breckow (Bankr. E.D. Mich. 2005) (Tucker, J.) (no WL citation available).
D. Dismissal Under Totality of Circumstances Test - Section 707(b)(3)(B)
1. There is no statutory presumption of non-abuse under Section 707(b)(3)(B)'s "totality of circumstances" test for a debtor whose "current monthly income" is less than or equal to the applicable state median. Debtor's actual ability to repay nonpriority unsecured debts in a hypothetical chapter 13 plan is part of “totality of circumstances” consideration, and in such instance the court must consider the debtor's actual and anticipated future income (as opposed to “current monthly income'). Case here dismissed as abusive because debtor could pay a 19% dividend (which equaled about $33,000), was making over $100,000 annually, and certain expenses were excessive. Case reviews the debate between Culhane/White and Judge Wedoff regarding whether "an above-median debtor's case may be dismissed based on his ability to pay under either section 707(b)(2) or (3)." As regards this debate, the Court states:
a. "The rationale of the Culhane-White Article is as follows: Section 707(b)(2) represents an attempt to remedy two pre-BAPCPA problems, as perceived by Congress. First, section 707(b)(2) establishes definitely that ability to pay, standing alone, is a sufficient ground for dismissal as an abuse. Some courts had previously taken a contrary view. Second, section 707(b)(2) establishes a “bright line” test for a debtor's “ability to pay.” One of the problems perceived by Congress in this context was the lack of uniformity of bankruptcy courts' decisions on this issue. According to the Culhane-White Article, part of this “bright line” test is the establishment of the median income as the dividing line for debtors whose ability to pay may serve as the basis for dismissal. According to the Culhane-White Article, “[t]o say that judges are free under section 707(b)(3) to substitute their own can-pay standards for Congress' means test would render the means test superfluous.” It would also go against the canons of statutory construction, requiring statutes to be interpreted so as to be consistent with each other and to give meaning to all parts.
b. The Debtor does not cite the Culhane-White Article. However, he argues along similar lines. He notes that the “means test” was established by Congress to eliminate the lack of uniformity in judicial decisions on motions to dismiss under section 707(b). By providing that the “means test” applies only to debtors whose “current monthly income” exceeds the median, according to the Debtor, Congress created a “safe harbor” for all other debtors. Any other view would reintroduce the very judicial discretion that BAPCPA sought to eliminate. The Debtor also quotes various statements by members of Congress, predicting that BAPCPA will have no effect on debtors whose income is not above the median.
c. The Debtor recognizes that, but for the timing of his unemployment and the statutory definition of “current monthly income,” he would fall into the category of debtors that Congress wished to subject to the “means test.” However, he notes that this potentiality was “absolutely predictable to legislators.” If Congress had wished to prevent such debtors from falling through the statutory cracks, it could have provided an express provision preventing them from doing so. Courts may not remedy what Congress failed to do….
d. The Debtor relies heavily on Congress's stated intention, in enacting BAPCPA, to severely limit judicial discretion with respect to section 707(b) motions so as to establish more uniformity. He argues that, by construing section 707(b)(3) as including a consideration of the debtor's ability to repay, Congressional intent is subverted and judicial discretion is reintroduced into the system. He also cites statements from the Congressional Record, assuring the public that the below-median-income debtor's right to obtain bankruptcy relief will not be affected. The Court is not persuaded by these arguments. First, while BAPCPA did severely limit judicial discretion for above-median-income debtors, judicial discretion has not been entirely eliminated. As noted above, the presumption of abuse may be rebutted by evidence of “special circumstances.” As to equal to or below-median-income debtors, clearly, judicial discretion will have to be applied to consider the “totality of the circumstances” whether or not those circumstances include consideration of a debtor's ability to pay. Finally, a debtor earning over $100,000 a year cannot fairly complain of being misled by Congressional statements that low income debtors' rights to bankruptcy relief will not be affected by BAPCPA. For all of these reasons, the Court concludes that the Debtor's actual ability to repay his nonpriority unsecured debts may be considered as part of the totality of circumstances of his financial situation pursuant to section 707(b)(3)." In re Pak, 343 B.R. 239 (Bankr. N.D. Cal. 2006) (Tchaikovsky, J.).
E. Dismissal for Substantial Abuse
1. In calculating chapter 7 debtor's disposable income and ability to fund a Chapter 13 plan, for purpose of deciding whether to dismiss Chapter 7 case as "substantial abuse," court will assume that debtor with documented history of working overtime will continue to do so, and consider such overtime as bearing on debtor's income, unless debtor demonstrates why such overtime work will not be available to him or that he will be unable to take advantage of available overtime. Case dismissed where debtor had sufficient disposable income to make significant payment on unsecured debt in hypothetical, 36-month Chapter 13 plan, even without the belt-tightening that expenditure of $72 per month on cable television suggested as possibility. Also, debtor showed lack of honesty in significantly underreporting his income when he filed his petition and accompanying schedules. In re Reeves, 327 B.R. 436 (Bankr. W.D. Mo. 2005) (Dow, J.).
2. "Although Chapter 7 is not exclusively for persons who have suffered adversity, it is not a financial planning device to ensure that only sacrifices that ever need to be suffered in order to accomplish debtor's life-style choices will be sacrifices that are to be suffered only by debtor's creditors…. Platitudes abound to the effect that bankruptcy affords the 'honest but unfortunate' debtor a 'fresh start,' but not a 'head start.' These Debtors are honest, but not unfortunate. They don't need a 'fresh start.' What they hope for from the Court is a 'head start' on their children's higher education. That this case is distinguishable from cases involving calamity is obvious. But this case is also distinguishable from the hypothetical case of people just starting out in life who, having made unwise or naive decisions in the course of trying to establish themselves in an occupation or career, face the choice of putting their future on hold for three to five years in Chapter 13, or of availing themselves of the 'fresh start' Congress envisioned. The distinction between such a hypothetical case and the case at bar rests in the otherwise trite phrase, 'What did you expect?' When the expectation had been of a good-paying job at the end of course of study or apprenticeship, and those expectations have been dashed, a 'fresh start' in Chapter 7 may be appropriate. But not where, as here, a long course of calculated conduct turns out to present an inconvenience once it turns out that there is more one wants to do for one's child, or parent, or community. It is also distinguishable from the hypothetical case of persons who, at any stage of life, made a terrible mistake that put them at risk for keeping body and soul together for the future. The enormous increase in filing by the elderly in this Court in recent years has been a source of alarm and sadness for this writer." In re Godios, 333 B.R. 644 (Bankr. W.D.N.Y. 2005) (Kaplan, J.).
3. Use of contested matter rather than adversary proceeding to resolve motion to dismiss Chapter 7 case as “substantial abuse” of provisions of that chapter did not deprive debtor of opportunity for discovery or for trial. Also, debtor's filing of chapter 7 petition 17 months after accumulating about $120,000, or twice his annual household income, in credit card debt was not "substantial abuse." Nothing in record suggested that debtor contemplated filing for chapter 7 relief at time he incurred this credit card debt. Also, debtor's subsequent loss of employment and separation from wife were intervening changes in circumstances. Further, when chapter 7 petition was filed, debtor did not have ability to repay his debts. Khachikyan v. Hahn (In re Khachikyan), 335 B.R. 121 (Bankr. 9th Cir. 2005) (Klein, J.).
4. Chapter 7 debtor's ability to fund Chapter 13 plan is primary factor for court to consider in deciding whether case should be dismissed as “substantial abuse” of provisions of Chapter 7. The debtor's ability to pay creditors is measured, for “substantial abuse” dismissal purposes, by evaluating debtor's financial condition in hypothetical chapter 13 proceeding. Here, debtor who was seeking to discharge $95,000 in credit card debt, and had $1,500 in discretionary expenditures (including $700 per month as home schooling expense for child performing at average level in public school and $500 per month for skating lessons and competitions). Court dismissed case as “substantial abuse,” where debtor, by trimming expenses, could pay over $29,000–or roughly 30%–of his unsecured creditors in hypothetical three-year Chapter 13 plan. In re Stout, 336 B.R. 138 (Bankr. N.D. Iowa) (Kilburg, J.).
F. 341 Meetings
1. Meeting not "held" until conclusion of 341 meeting. Virginia law defines exemption by reference to when 341 meeting "held." In re Stewart (Bankr. E.D. Va. 2006) (Adams, J.). (no WL citation available).
2. FRBP 2003(e), which permits first meeting of creditors to be adjourned “by announcement at the meeting of the adjourned date and time without further written notice” does not require announcement at meeting as to the date when meeting will be adjourned to as exclusive manner for such an adjournment. Rule merely relieves trustee of need to provide written notice if such an announcement is made. First meeting does not automatically conclude, so as to start 30-day deadline for objecting to debtor's claimed exemptions, merely because trustee fails to announce on the record at meeting a specific date on which meeting will continue. Rather, after meeting adjourns, trustee may continue the meeting by written notice. Such notice may be appropriate where debtor fails to appear at initial meeting, or where debtor's financial affairs are complex and require further investigation or review before trustee is able to determine whether further examination of debtor is required. Chapter 7 debtors waived right to object to trustee's continuance by continuing to cooperate with trustee, never contesting trustee's authority, and appearing and cooperating at reconvened meeting. Accordingly, objections to debtors' claimed exemptions, which were filed within 30 days of date that reconvened meeting of creditors was concluded, were also timely on waiver theory. In re Cherry, 341 B.R. 581 (Bankr. S.D. Tex. 2006) (Isgur, J.).
G. Involuntary Petition
1. Putative debtor's admissions at crime scene that he had fatally shot party whose probate estate was asserting wrongful death claim, and whose children were asserting emotional distress and support and personal injury claims through their conservator, in conjunction with other evidence included in state court's decision on putative debtor's motion to suppress evidence, established prima facie claims purposes of joining in involuntary chapter 7 petition. Burden thus shifts to putative debtor to establish that probate estate's and children's claims were subject to bona fide dispute that would disqualify them from joining in the involuntary petition. Metz v. Dilley (In re Dilley), 339 B.R. 1 (Bankr. 1st Cir. 2006) (Rosenthal, J.).
H. Pre-Discharge Financial Management Course
1. The financial management course must be completed “after filing the petition” in order to be eligible to receive a discharge. A prepetition course does not satisfy the requirement. In re Skarbek, 2005 WL 3348879 (Bankr. W.D. Pa. 12/6/05) (Bentz, J.); In re Granda, 2005 WL 3348878 (Bankr. W.D. Pa. 12/6/05) (Bentz, J.).
2. Completion of prepetition counseling class doesn't satisfy requirement of postpetition financial management training. In re Fuller, 2005 WL 3454699 (Bankr. W.D. Pa. 2005) (Bentz, J.) (see also In re Rodgers, 2005 WL 3454702 and In re Stidham, 2005 WL 3454709 (Bankr. W.D. Pa. 2005) (companion opinions of Judge Bentz)).
3. Section 727(a)(11) requires a course be completed before discharge. Rule 1007 requires certification that the course was completed no later than 45 days after the first meeting of creditors. If not obtained, case will be closed without the discharge. Case can be reopened upon request, but reopening fee must be paid. In re Martinez, 2006 WL 681068 (Bankr. N.D. Iowa 2006) (Kilburg, J.).
4. Chapter 7 debtors who fail to submit statement of completion of financial management court not entitled to discharge. Cases are to be closed without discharge and should they later complete course, they may seek to reopen case to enter discharge. In re Smiley (Bankr. E.D. Mich. 2006) (Shefferly, J.) (no WL citation available)
I. Simultaneous Filings
1. The courts are divided on the question whether, pre-BAPCPA, a simultaneous “Chapter 20” filing is ever permissible. The majority has endorsed a per se rule prohibiting a debtor from having more than one bankruptcy case open at any time. Although courts have differed on the permissibility of “simultaneous Chapter 20” cases, there is general agreement that a debtor may not maintain two or more concurrent actions with respect to the same debts, with only the Tenth Circuit holding otherwise. In re Sidebottom, 430 F.3d 893 (7th Cir. 2005) (Wood, J.).
[NB: Certain links are to Westlaw. Those who do not have access to Westlaw may contact me directly if they would like to view a particular case, though all federal courts maintain their own websites where judicial opinions may be accessed by the public free of charge (e.g., Bankr. N.D. Ill. - Judge Wedoff opinions). Because all the outline's case references identify the deciding judge, you should be able to find the opinions online with minimal effort.]
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What a great collection of information. Nice, very nice and valuable post. Thanks for introducing about chapter 7 bankruptcy details...DIY4LAW