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§ 524(c)

In re Minardi

Ruling
Reaffirmation agreement could not be approved absent counsel's required declaration regardless of liability concerns.
Procedural posture

The debtor moved for approval of a reaffirmation agreement. Debtor's counsel, however, refused to provide the declaration required by 11 U.S.C.S. § 524(c)(3).

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Consumer opinion summary, case decided on January 23, 2009 , LexisNexis #0409-007

In re Polkus

Ruling
Objection to debtor's recission of reaffirmation agreement overruled.
Procedural posture

Chapter 7 debtors sought the rescission of a reaffirmation agreement under 11 U.S.C.S. § 524(c)(4). The creditor objected, asserting that the debtors' rescission was untimely and that the creditor had not been properly noticed in writing of the debtors' rescission.

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Consumer opinion summary, case decided on December 03, 2008 , LexisNexis #0109-050

In re Caraballo

Ruling
Reaffirmation of debt secured by real property was not in debtor's best interests due to continued availability of ride-through option.
Procedural posture

A debtor filed for relief under chapter 7 of the Bankruptcy Code. The debtor opted to reaffirm a secured debt on the debtor's real property, pursuant to 11 U.S.C.S. § 524(c). The debtor had filed a motion for approval of reaffirmation agreements, which the court orally granted and then vacated for a further hearing. After the hearing, the court issued findings.

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Consumer opinion summary, case decided on April 29, 2008 , LexisNexis #0608-010

In re Rodriguez

Ruling
Reaffirmation agreement ineffective due to failure to included completed Parts C and D.
Procedural posture

A debtor and a creditor proposed a reaffirmation agreement.

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Consumer opinion summary, case decided on March 03, 2008 , LexisNexis #0508-012

In re Gonzalez

Ruling
Reaffirmation agreement could not be approved due to failure of counsel to opine on ability of debtor to make payments.
Procedural posture

A debtor and a creditor proposed a reaffirmation agreement, pursuant to 11 U.S.C.S. § 524(c).

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Consumer opinion summary, case decided on February 11, 2008 , LexisNexis #0308-080

In re Chim

Ruling
Court declined to approve reaffirmation agreement due to presumption of undue hardship.
Procedural posture

Chapter 7 debtor filed a motion to approve a reaffirmation agreement with a lender pursuant to 11 U.S.C.S. § 524(c).

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Consumer opinion summary, case decided on January 25, 2008 , LexisNexis #0208-117

In re Young

Ruling
Court lacked power to approve reaffirmation agreement once discharge was entered.
Procedural posture

A debtor filed a motion to reopen a chapter 7 bankruptcy case to file a reaffirmation agreement with a creditor.

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Consumer opinion summary, case decided on November 29, 2007 , LexisNexis #1207-118

In re Kidwell

Ruling
Motion to redeem motor vehicle effectively amended debtor's prior statement of intent to reaffirm.
Procedural posture

The debtor moved to redeem his motor vehicle from the secured creditor thereof, and the creditor objected. At issue was whether the debtor was bound by his prior statement of intent to reaffirm the debt, and if he was not bound, what value should be assigned to the vehicle for purposes of redemption. The creditor argued that the debtor failed to timely amend his statement of intent to reaffirm, and was not entitled to redeem the vehicle.

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Consumer opinion summary, case decided on October 04, 2007 , LexisNexis #1107-010

In re Vaupel

Ruling
Bankruptcy court declined to approve stipulation based on reaffirmation agreement that would not have been approved.
Procedural posture

The debtors filed for relief under chapter 13, and the matter was converted to a case under chapter 7. The creditor held a security interest in an automobile. The debtor and the creditor filed a reaffirmation agreement reaffirming the debt to the credit union in the amount of $3,397. The parties filed an agreed joint stipulation and order between the debtor and the creditor.

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opinion summary, case decided on August 28, 2007 , LexisNexis #1007-006

In re Miller

Ruling
Reaffirmation of loan secured by motorcycle denied as not in debtor's best interest.
Procedural posture

A debtor filed a reaffirmation agreement with a creditor in order to retain a motorcycle, and the court held a hearing in order to evaluate the reasonableness of the reaffirmation.

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opinion summary, case decided on August 20, 2007 , LexisNexis #0907-085