Rizzo v. Mindes (In re Mindes)

Default judgment that did not establish fraud was not basis for nondischargeable debt.
Procedural posture: 
Judgment creditors brought an adversary proceeding against debtor seeking a determination that a debt to the creditors was nondischargeable under 11 U.S.C.S. § 523(a)(2) based on the debtor's fraudulent representation that the debtor would perform remodeling and construction on the creditors' property.
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Consumer case opionion summary, case decided on April 02,2009, LexisNexis #0609-050