In re Shankman

Trustee could amend dischargeability complaint to reflect misconduct occurring after deadline for objection but prior to discharge.
Procedural posture: 
Plaintiff bankruptcy trustee brought an adversary proceeding against defendant bankruptcy debtor objecting to the debtor's discharge on various grounds. The trustee moved for leave to amend the complaint to allege additional grounds for denial of the debtor's discharge.
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Consumer case opionion summary, case decided on September 01,2009, LexisNexis #1009-033