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eastern district of wisconsin

In re Thongta

Ruling
Insurance company violated stay by docketing judgment against non-debtor spouse and creating lien against property of the estate.
Procedural posture

A debtor filed for relief under chapter 13 and a non-filing spouse did not join in the petition. A plan was confirmed. The debtor sought sanctions against an insurance company for alleged violations of 11 U.S.C.S. §§ 362 and 1301 when it filed a small claims action against the non-filing spouse.

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Consumer opinion summary, case decided on March 24, 2009 , LexisNexis #0509-107

In re Delp

Ruling
Confirmation of amended plan denied due to unwarranted deduction in proposed payments.
Procedural posture

The debtors filed a chapter 13 petition. After the debtors filed their first and second amended plans, the trustee objected pursuant to 11 U.S.C.S. § 1325(a)(3) on the grounds that the debtors reduced their plan payments by $ 472 per month without providing any supporting documentation or explanation. The bankruptcy court held a hearing on the trustee's objection.

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Consumer opinion summary, case decided on February 09, 2009 , LexisNexis #0309-131

In re Bermann

Ruling
Chapter 13 debtor could deduct projected taxes and insurance costs even though not required as an escrow payment.
Procedural posture

A debtor filed for relief under chapter 13, and filed an amended plan. A chapter 13 trustee objected to confirmation of the debtor's amended plan, pursuant to 11 U.S.C.S. § 1325(b)(1).

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Consumer opinion summary, case decided on January 16, 2009 , LexisNexis #0209-092

In re Van Beckum

Ruling
Property tax claim disallowed as in excess of value of real property.
Procedural posture

The chapter 13 debtors objected to the proofs of secured claim filed by the county for delinquent property taxes and penalties and by the sanitary district for sewer and water charges.

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Consumer opinion summary, case decided on January 15, 2009 , LexisNexis #0309-007

In re Larsen

Ruling
Case dismissed where incarcerated debtor did not request prepetition briefing from credit counselor or cite exigent circumstances for exemption.
Procedural posture

A chapter 7 debtor filed a motion for an exemption from the credit counseling requirement under 11 U.S.C.S. § 109(h)(4).

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Consumer opinion summary, case decided on January 09, 2009 , LexisNexis #0209-072

Neary v. Leech (In re Leech)

Ruling
Discharge denied due to debtor's omission of jewelry from schedules.
Procedural posture

United States trustee filed an action against defendant debtor to deny a discharge to the debtor pursuant to 11 U.S.C.S. §§ 727(a)(2) and (4) of the United States Bankruptcy Code. The trustee also objected to certain objections claimed by the debtor.

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Consumer opinion summary, case decided on January 08, 2009 , LexisNexis #0909-016

In re Mravik

Ruling
Debtor's ongoing contribution to 457 pension plan did not require dismissal for abuse.
Procedural posture

The trustee, asked the court to dismiss debtor's chapter 7 petition for abuse under 11 U.S.C.S. § 707(b)(1), 707(b)(2), or 707(b)(3). At issue was whether debtor's ongoing contribution to a so-called "I.R.C. § 457" pension plan sponsored by her public employer constituted "abuse" authorizing dismissal of her petition.

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Consumer opinion summary, case decided on December 31, 2008 , LexisNexis #0209-080

Ruhl v. HSBC Mortg. Servs.

Ruling
Debtors could not contest interest on mortgage arrears that they themselves proposed to pay in their confirmed plans.
Procedural posture

Appellant chapter 13 debtors challenged decisions of the bankruptcy court for the Eastern District of Wisconsin, which granted appellee lenders'motions to dismiss the debtors'adversary proceedings on the grounds that their claims were barred by the principle of finality embodied in 11 U.S.C.S. § 1327(a). The cases were consolidated on appeal.

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Consumer opinion summary, case decided on December 23, 2008 , LexisNexis #0209-033

Swanson v. M&I Marshall (In re Vission Inc.)

Ruling
Lien that was perfected during preference period could be avoided.
Procedural posture

A debtor filed for relief under chapter 7 of the Bankruptcy Code. Plaintiff filed an action against defendant, a limited liability company (LLC) to avoid a lien given to the LLC, pursuant to 11 U.S.C.S. §§ 544 and 547, asserting that the transfer was preferential. The court issued findings and facts and conclusions of law. The trustee sought judgment on the pleadings.

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Commercial opinion summary, case decided on December 10, 2008 , LexisNexis #0309-083

In re Patton

Ruling
Plan could require mortgage creditors to apply payments as if prepetition default had not occurred.
Procedural posture

Chapter 13 debtors filed plans containing language objectionable to secured creditors, all of whom were home lenders. The plans' proposed language provided that the payments would be applied to the debtors' mortgage accounts as if the accounts were current and no prepetition defaults existed on the petition dates, and the creditors argued that those provisions impermissibly modified their secured liens in violation of 11 U.S.C.S. § 1322(b)(2).

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Consumer opinion summary, case decided on November 19, 2008 , LexisNexis #0209-056