In re Kimsel

Foreclosure sale on filing date did not create exigent circumstances sufficient to justify waiver of credit counseling requirement.
Procedural posture: 
A debtor requested a waiver, based on exigent circumstances, of the requirement in 11 U.S.C. § 109(h) that he obtain credit counseling prior to the filing of his chapter 13 bankruptcy petition. The debtor requested an additional 30 days in which to obtain the counseling.
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