In re Lilliefors

Debtor who falsely certified compliance with credit counseling requirement could not benefit from actual non-compliance by obtaining voluntary dismissal.
Procedural posture: 
The debtor had stated under oath that he completed the credit counseling requirement and would file the credit counseling certificate. However, he did not file the certificate. Because there were assets available for distribution to creditors, both the chapter 7 trustee and the United States Trustee filed motions to prevent the case from being dismissed under Interim Bankr. E.D. Va. R. 1007-1(J)(4).
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Consumer case opionion summary, case decided on October 03,2007, LexisNexis #1107-004