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Kowalski, In re

Ruling: 
Case converted to chapter 7 as there was continuing loss or diminution and an absence of a reasonable likelihood of rehabilitation. (Bankr. N.D. Ill.)
Issue: 
Conversion or Dismissal; Involuntary Conversion or Dismissal; What Constitutes “Cause”; Loss or Diminution of Estate.
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Consumer case opionion summary, case decided on November 30,2018, LexisNexis #0119-048