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§ 109

In re DiPinto

Ruling
Waiver of credit counseling requirement was denied, and the case was dismissed since the debtor had failed to demonstrate that the debtor had sought counseling in advance of filing.
Procedural posture

Debtor filed a chapter 13 petition without having first obtained credit counseling as required by the Bankruptcy Abuse Prevention and Consumer Protection Act. In lieu of a certificate reflecting completion of credit counseling, debtor's counsel filed a request for a waiver of that requirement, pursuant to 11 U.S.C. § 109(h)(3).

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opinion summary, case decided on January 30, 2006 , LexisNexis #0206-053

In re Shepard

Ruling
Debtor husband was ineligible for chapter 13 relief because the debtor husband's unsecured claims exceeded the statutory limit.
Procedural posture

Bankruptcy debtors, husband and wife, filed a joint chapter 13 bankruptcy petition, but the debtors did not identify as an asset a condominium that was co-owned by the husband and a daughter. A lender which financed the purchase of the condominium filed a proof of a secured mortgage claim, and the trustee moved to dismiss the debtors petition based on debt limits under 11 U.S.C. § 109(e).

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opinion summary, case decided on January 25, 2006 , LexisNexis #0206-062

In re Slocum Lake Drainage Dist.

Ruling
Debtor's case was dismissed since the debtor was not authorized under Illinois law to file a petition under chapter 9.
Procedural posture

The debtor, a county drainage district located in the State of Illinois petitioned for bankruptcy relief pursuant to chapter 9. The movant creditor sought dismissal of the petition pursuant to 11 U.S.C. § 921(c), because it contended that the debtor was not authorized under Illinois law to file a petition under chapter 9, as required by 11 U.S.C. § 109(c)(2).

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opinion summary, case decided on January 19, 2006 , LexisNexis #0206-086

In re Henderson

Ruling
Debtor was denied an extension to file a credit counseling certificate but given time to obtain further legal advice since the debtor had not shown sufficient exigent circumstances to warrant the extension.
Procedural posture

Petitioner debtor filed a petition for relief under chapter 13 of the Bankruptcy Code. On that same day, she also filed a Request for Thirty-Day Extension To File Credit Counseling Certificate, which was before the court for a decision.

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opinion summary, case decided on January 17, 2006 , LexisNexis #0406-037

In re Buis

Ruling
Debtors'chapter 13 case was dismissed on a creditor's motion since the creditor's claim of attorneys'fees incurred in obtaining a judgment against the debtors was a noncontingent, liquidated claim that put the debtors over the unsecured debt limit.
Procedural posture

Creditor filed a motion to dismiss chapter 13 debtors'case or convert it to a case under chapter 7.

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opinion summary, case decided on January 11, 2006 , LexisNexis #0206-063

In re Schmidt

Ruling
Debtors'chapter 13 case was dismissed since they failed to show they had sufficient income to fund a plan and because their noncontingent, liquidated, unsecured debts exceeded the statutory limit.
Procedural posture

Debtors filed for bankruptcy relief under chapter 13. The creditors filed two motions to dismiss the petition and a motion to show cause why the bankruptcy proceeding should not be dismissed. The creditors contended that the debtors were not eligible for chapter 13 relief, pursuant to 11 U.S.C. § 109(e), that the debtors did not file in good faith.

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opinion summary, case decided on January 04, 2006 , LexisNexis #0206-098

In re Rodriguez

Ruling
Debtors'case was dismissed since they failed to justify their request for a waiver of the credit counseling certification requirement.
Procedural posture

Debtors filed a voluntary joint bankruptcy petition under chapter 13. The debtors filed a request for waiver of timely filing of an 11 U.S.C. § 109(h) credit counseling certificate.

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opinion summary, case decided on December 09, 2005 , LexisNexis #0206-051

In re Davenport

Ruling
Debtor was not excused from prepetition credit counseling requirement despite exigent circumstances because the debtor failed to make a prefiling request for counseling.
Procedural posture

The debtor filed a motion to be excused from complying with the prepetition credit counseling requirement of 11 U.S.C. § 109(h), alleging only that certain "exigent circumstances" — the imminent repossession of the debtor's truck — made prepetition credit counseling "meaningless." Two days after filing the petition, the debtor did receive the approved credit counseling.

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opinion summary, case decided on December 06, 2005 , LexisNexis #0106-037

Mortg. Elec. Registration Sys. v. Townsend (In re Townsend)

Ruling
Court denied the debtor's emergency motion to reconsider a section 109(g) dismissal order since the debtor failed to file a court-requested affidivat of making chapter 13 plan payments or postpetition mortgage arrearages.
Procedural posture

Debtor filed a pro se motion styled as "Emergency Motion to Reconsider Order of Dismissal Pursuant to 11 U.S.C. § 109(g) to Shorten Time for Notice and to Permit Re-Filing." The motion was opposed by creditor, which filed a request to deny debtor's Emergency Motion.

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opinion summary, case decided on December 02, 2005 , LexisNexis #0306-040

In re Talib

Ruling
Debtor's motion to waive pre-filing debt counseling requirement was denied since she did not establish exigent circumstances.
Procedural posture

Pursuant to 11 U.S.C. § 109(h)(3), a chapter 13 debtor filed a certification of exigent circumstances and a motion to waive debt counseling prior to filing.

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opinion summary, case decided on December 01, 2005 , LexisNexis #0106-001