In re Thomas

Ruling: 
Debtor was denied a waiver of the prefiling credit counseling requirement since the debtor's certificate of exigent circumstances failed to state that the debtor requested the counseling before filing.
Procedural posture: 
With his petition, the debtor requested a temporary waiver of the prefiling credit counseling requirement required by 11 U.S.C. § 109(h)(1) due to exigent circumstances. The debtor cited to a "foreclosure date" on his home as the exigent circumstance.
Issue: 
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