Sergio v. Garcia (In re Garcia)

Chapter 13 case dismissed due to total unsecured debt in excess of jurisdictional limits.
Whether debtor has too much unsecured debt to be in a Chapter 13 case, turning on whether debtor's wholly unsecured junior mortgages count as unsecured debts under § 109(e)?
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Consumer case opionion summary, case decided on October 03,2014, LexisNexis #1014-108