In re Ramos

Ruling: 
Debtor could not modify plan postconfirmation before completion of payments to provide for surrender of collateral.
Issue: 
Could chapter debtor modify confirmed plan to provide for surrender of property as full payment of claim where direct payments on the mortgage called for by the plan had not been made?
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Consumer case opionion summary, case decided on November 13,2015, LexisNexis #1215-100