In re Allen

Ruling: 
Court dismissed the debtor's case since the debtor's certificate of exigent circumstances regarding the prefiling credit counseling requirement was deficient.
Procedural posture: 
The debtor filed a voluntary petition for relief under chapter 13 of the Bankruptcy Code and a certification of exigent circumstances as to why she had not obtained credit counseling, as required by 11 U.S.C. § 109(h). The court held that the certificate was deficient because it lacked a statement that the debtor had attempted but was unable to obtain the required counseling, and it granted the debtor leave to file a supplemental certificate.
Issue: 
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