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In re Buffalo Coal Co.

Ruling
Portion of proceeds of sale of estate property placed in escrow pending determination of which party was entitled to funds.
Procedural posture

After the debtor filed a chapter 11 bankruptcy petition, it proposed to package an unexpired lease of nonresidential property, the related mining permits, and other assets for sale. The court approved the sale after a hearing, but ordered that a portion of the purchase price be placed in escrow pending resolution of the character of those funds. The court issued a memorandum to explain its rationale.

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opinion summary, case decided on November 15, 2006 , LexisNexis #1206-040

In re Nice

Ruling
Cramdown of automobile loan allowed for presumptive replacement value in pre-BAPCPA case.
Procedural posture

Chapter 13 debtor filed a motion pursuant to 11 U.S.C. § 1325(a)(5)(B) to cram down the value of creditor's secured claim against her personal vehicle from $56,600 to $36,050.

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opinion summary, case decided on October 30, 2006 , LexisNexis #1206-140

In re Lee

Ruling
Debtors could not reopen case to file amended versions of deficient reaffirmation agreements.
Procedural posture

Debtors moved to reopen, pursuant to 11 U.S.C. § 350(b), their discharged chapter 7 bankruptcy case to file two amended reaffirmation agreements to replace similar agreements that had been found to be defective and unenforceable, under 11 U.S.C. § 524. Debtors were attempting to refinance their real property and payoff the existing debts on their home and car.

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opinion summary, case decided on October 30, 2006 , LexisNexis #1206-108

Eddy v. Educational Credit Management Corp. (In re Eddy)

Ruling
Debtor with no disabilities or medical conditions who did not make good faith effort to pay denied discharge of student loan debt.
Procedural posture

Plaintiff debtor filed an adversary proceeding against defendant creditor to determine the dischargeability of certain student loan obligations pursuant to 11 U.S.C. § 523(a)(8).

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opinion summary, case decided on September 28, 2006 , LexisNexis #1206-024

McNemar v. Student Loan Servicing Center (In re McNemar)

Ruling
Debtor who made voluntary decision to cease payments denied undue hardship discharge of student loan debt.
Procedural posture

Plaintiff debtor filed an adversary proceeding against defendant creditor to determine the dischargeability of certain student loan obligations pursuant to 11 U.S.C. § 523(a)(8).

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opinion summary, case decided on September 28, 2006 , LexisNexis #1206-025

In re Lackey

Ruling
Reconsideration of dismissal for failure to comply with credit counseling requirements of BAPCPA denied.
Procedural posture

Debtor, pro se, filed a motion to reconsider the court's order dismissing his chapter 13 case based on his failure to obtain a prepetition, budget and credit counseling briefing, and based on his ineligibility to obtain a postponement or waiver of that requirement.

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opinion summary, case decided on September 14, 2006 , LexisNexis #1106-071

In re Brown

Ruling
Debtor's motion to purchase cause of action from estate in closed case granted over objection of potential defendant.
Procedural posture

After bankruptcy debtors'case was closed, the debtors'former mortgagee filed an eviction action against the debtors and the debtors counterclaimed on the ground that the mortgagee engaged in improper debt collection activities. After the case was reopened, the trustee moved for leave to release the debtors' prepetition cause of action against the mortgagee to the debtors in exchange for a cash payment.

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opinion summary, case decided on September 01, 2006 , LexisNexis #1106-099

Boyd v. Household Auto Fin. (In re Boyd)

Ruling
Creditor's default in adversary proceeding was due to neglect of seven court notices which was not excusable.
Procedural posture

Plaintiff chapter 7 trustee filed an adversary proceeding against defendant creditor to avoid its lien on the debtors'vehicle as being a preferential transfer under 11 U.S.C. § 547. The creditor did not respond and a default judgment was entered against it. The creditor moved for relief from the default judgment pursuant to the "excusable neglect" standard of Fed. R. Civ. P. 60(b)(1), made applicable to bankruptcy by Fed. R. Bankr. P. 9024.

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opinion summary, case decided on August 11, 2006 , LexisNexis #0906-027

Walters Construction Inc. v. Cook (In re Cook)

Ruling
Creditor was not entitled to summary judgment that debt was excepted from discharge for fraud absent showing of scienter.
Procedural posture

Plaintiff contractor sued defendant chapter 7 debtor, seeking to exempt a $17,000 debt from discharge pursuant to 11 U.S.C. § 523(a)(2)(A) or (B) on the grounds that the debtor falsely certified a subcontractor's payroll records. The creditor moved for summary judgment.

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opinion summary, case decided on August 08, 2006 , LexisNexis #0906-004

In re Hall

Ruling
Eighty-one-year-old debtor with severe physical impairment and health issues granted disability waiver of personal financial management course.
Procedural posture

A debtor filed a renewed motion for an exemption from the requirement of 11 U.S.C. § 727(a)(11) that he participate in the instructional course concerning personal financial management before being entitled to a chapter 7 discharge.

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opinion summary, case decided on August 04, 2006 , LexisNexis #0906-046