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§ 1329

In re Racine

Ruling
Modification granted due to increased income and expenses.
Procedural posture

Bankruptcy debtors asserted that their financial circumstances warranted reduction of monthly payments and payments to claims under their confirmed plan. The debtors moved to modify their plan, and the bankruptcy trustee objected to modification.

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Consumer opinion summary, case decided on February 01, 2013 , LexisNexis #0213-136

Colon v. Santander Fin. Servs. Corp. (In re Colon)

Ruling
Trustee's postconfirmation request to include settlement proceeds in plan had to be filed as motion in lead case.
Procedural posture

The chapter 13 Trustee moved for entry of an Order directing (plaintiffs) debtors to pay into the Plan settlement funds, alleging that the monies which debtors would receive from a settlement were property of the estate pursuant to 11 U.S.C.S. § 1306 and thus, the same had to be paid into the plan as disposable income under 11 U.S.C.S. § 1325(b). Debtors filed an Opposition. Defendants were a creditor, two individuals and an insurance company.

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Consumer opinion summary, case decided on January 16, 2013 , LexisNexis #0213-065

DeHart v. Eckert (In re Eckert)

Ruling
Trustee's motion for excessive increase in monthly plan payments denied.
Procedural posture

Debtors, a husband and wife, declared chapter 13 bankruptcy and proposed a plan for paying their debts that required them to pay a chapter 13 trustee $500 per month. The court confirmed the debtors' plan on April 28, 2011, and on April 19, 2012, the trustee filed a motion for an order under 11 U.S.C.S. § 1329 which required the debtors to increase their monthly payment to $2,500. The court held a hearing on the trustee's motion.

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Consumer opinion summary, case decided on January 14, 2013 , LexisNexis #0213-031

In re Ward

Ruling
Postconfirmation modification granted over trustee's objection due to failure of debtor to realize anticipated substantial increase in income.
Procedural posture

Before the court was debtor's modification of plan after confirmation and the chapter 13 Trustee's objections thereto. Debtor filed this modification after confirmation (MAC) seeking to reduce the monthly payments to $200/month because debtor was unable to make the $2,500/month step up payment because his current income and expenses demonstrated the ability to pay less than the amount in the confirmed plan.

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Consumer opinion summary, case decided on August 24, 2012 , LexisNexis #0912-138

In re Harp

Ruling
Plan modification denied as retroactive and unfair to general unsecured creditors.
Procedural posture

Bankruptcy debtors who fell behind in payments under their confirmed plan sought to reduce their monthly payments and extend the term of the plan. The debtors moved to modify their confirmed plan.

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Consumer opinion summary, case decided on August 20, 2012 , LexisNexis #0912-067

Coay v. Coay (In re Coay)

Ruling
Trustee's motion to increase plan payments after debtor resumed work denied.
Procedural posture

Debtors, a husband and wife, declared chapter 13 bankruptcy and proposed a plan for paying their creditors. The court confirmed the debtors' second amended plan in January 2010, and in July 2011 a trustee who was appointed to administer the plan filed a motion for an order under 11 U.S.C.S. § 1329(a)(1) which required the debtors to increase plan payments. The debtors opposed the trustee's motion.

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Consumer opinion summary, case decided on June 19, 2012 , LexisNexis #0712-064

In re DelConte

Ruling
Debtor ordered to amend plan to reflect value of postconfirmation inheritance.
Procedural posture

Debtors filed a joint petition under chapter 13 of the Bankruptcy Code and proposed a plan for repaying their creditors. After the court confirmed the debtors' plan, a trustee who was appointed to administer the debtors' plan filed a motion seeking an order under 11 U.S.C.S. § 1329 which required the debtors to modify their plan. The court held a hearing on the trustee's motion.

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Consumer opinion summary, case decided on May 15, 2012 , LexisNexis #0612-032

Mattson v. Howe (In re Mattson)

Ruling
Debtors properly denied modification to shorten term of plan from five years to three years absent corresponding change in circumstances.
Procedural posture

Appellant above-median chapter 13 debtors challenged an order of the United States Bankruptcy Court for the Western District of Washington, denying debtors motion to modify their confirmed plan under 11 U.S.C.S. § 1329 to shorten the term of their plan from five years to three years, while increasing their payment amount due to a post-confirmation increase in income.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on April 05, 2012 , LexisNexis #0512-138

In re Ramirez

Ruling
Debtor could amend personal property schedules to include claim under Fair Debt Collection Practices Act.
Procedural posture

Debtor moved for reconsideration of an order that vacated a prior ruling denying a motion filed by a finance company in which it had objected to debtor's amendment of Schedule B. One issue was the effect of debtor's inclusion, on the amended schedule, of a claim, against the company, under the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (FDCPA), then being litigated in the district court.

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Consumer opinion summary, case decided on March 28, 2012 , LexisNexis #0512-105

In re Cluff

Ruling
Trustee's motion to modify debtor's confirmed plan denied absent evidence of increase in net income.
Procedural posture

Movant chapter 13 trustee filed a motion to modify debtor's confirmed chapter 13 bankruptcy plan because the debtor's marital status, income, and expenses had changed. The debtor opposed the trustee's motion.

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Consumer opinion summary, case decided on March 15, 2012 , LexisNexis #0412-065