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2024Posted: December 22, 2024 The National Association of Consumer Bankruptcy Attorneys (NACBA) is pleased to announce a significant legislative victory as Michigan’s House Bill 4901 (HB-4901) passed the State Senate in a 21-17 vote after an intense 29-hour session. Posted: December 16, 2024 NACBA is encouraged by their reintroduction of the Consumer Bankruptcy Reform Act, which aims to address longstanding challenges within the bankruptcy system. Posted: August 6, 2024 Delaware House Bill 318, an Act to Amend Title 10 and Title 19 of the Delaware Code Relating to Exemptions in Bankruptcy and Debt Proceedings, has been signed into law by Governor John Carney on August 2, 2024. Posted: May 28, 2024 On May 21, 2024 Governor Walz has signed the Minnesota Debt Fairness Act (SF 4097) into law. The Act introduces significant new bankruptcy exemptions for state debtors that take effect on August 1, 2024. Posted: April 27, 2024 A significant milestone was marked for individuals navigating bankruptcy in Florida as Governor Ron DeSantis signed SB158 into law on Friday, April 26, 2024. Posted: April 10, 2024 The National Association of Consumer Bankruptcy Attorneys (NACBA) is pleased to announce that on April 8, 2024 Virginia Governor Glenn Youngkin signed into law HB 1339, marking a significant step forward in aiding those seeking a fresh financial start within the state. Posted: April 8, 2024 The National Association of Consumer Bankruptcy Attorneys (NACBA) celebrates the enactment of SB 1595, known as the Family Financial Protection Act (FFPA), as Governor Kotek of Oregon signed it into law on April 4, 2024. Posted: April 4, 2024 The National Association of Consumer Bankruptcy Attorneys (NACBA) is thrilled to announce the 2024 recipient of the prestigious Henry J. Sommer Legal Aid Scholarship. Jayme Wiebold, a dedicated legal aid attorney and passionate consumer advocate, has been selected for this honor. Posted: April 1, 2024 NACBA applauds the passage of SB 1595, the Family Financial Protection Act (FFPA). This landmark legislation, approved with bipartisan support, has been years in the making and represents a significant victory for Oregon families. 2023Posted: December 20, 2023 The National Association of Consumer Bankruptcy Attorneys (NACBA) is pleased to inform that President Biden signed into law H.R.3315, the National Guard and Reservists Debt Relief Extension Act of 2023 on December 19, 2023. Posted: December 15, 2023 The National Association of Consumer Bankruptcy Attorneys (NACBA) is pleased to announce the successful passage of H.R.3315, the National Guard and Reservists Debt Relief Extension Act of 2023, by the United States Senate. Posted: November 17, 2023 At the time, both the departments committed to assessing the guidance after the first year of implementation. To do so, the Justice Department surveyed all 94 U.S. Attorneys’ Offices and consulted closely with the Department of Education to gather data and comments on the process. A dedicated group of experts within the Civil Division also collected input on the new process from consumer law groups, including the National Association of Consumer Bankruptcy Attorneys. Posted: October 10, 2023 The National Association of Consumer Bankruptcy Attorneys (NACBA) and the National Association of Student Loan Lawyers (NASLL) are pleased to announce the appointment of Ed Boltz as an alternate representative to the Department of Education Negotiated Rulemaking ("Neg Reg") Student Loan Debt Relief Committee on behalf of NACBA and NASLL. Boltz will serve as an advocate for consumer interests and the concerns of our client constituency, contributing to the Biden-Harris Administration's efforts to provide debt relief to as many student loan borrowers as possible. Posted: September 19, 2023 The National Association of Student Loan Lawyers (NASLL), the National Association of Consumer Advocates (NACA) and the National Association of Consumer Bankruptcy Attorneys (NACBA) write to request that the Department of Education broaden the number and scope of stakeholders that are invited to participate in the upcoming negotiated rulemaking regarding "its work to open a new pathway to student debt relief". Posted: July 12, 2023 The U.S. Supreme Court recently issued its opinion in Biden v. Nebraska in which it ruled that President Biden’s plan to cancel up to $20,000 in student loan debt per borrower under the CARES Act was beyond his constitutional authority. NACBA is disappointed in the Court’s decision as the plan would have afforded broad relief to millions of borrowers who are struggling under historic amounts of student loan debt. Posted: June 30, 2023 If you paid fees to access federal court records on PACER at any time between April 21, 2010 and May 31, 2018, a proposed class action settlement may affect your rights. Posted: June 30, 2023 NACBA’s New Jersey Working Group, in partnership with NCLC, NJ Appleseed and NJ Citizen Action, have been working to craft & advocate for a state homestead exemption law in NJ to protect families from losing their homes & safeguard essential needs from debt collectors. Posted: June 28, 2023 NACBA's MI working group has collaborated closely with Senator Cavanagh to ensure that Michigan families are granted a fresh start and are protected from losing their homes, cars, and public benefits to creditors. Posted: June 27, 2023 On March 16, 2023, the New Mexico Legislature passed SB 216, sweeping legislation which significantly increases the homestead exemption for New Mexicans from $60,000.00 per person up to $150,000.00 per person effective July 1, 2023. Posted: May 15, 2023 We have another victory in Washington State! The Fair Shot Act (SB 5173/HB 1400) was signed into law by Governor Inslee on May 9th and goes into effect on July 23, 2023. Posted: May 11, 2023 The National Consumer Bankruptcy Rights Center (NCBRC) is pleased to announce the appointment of James J. Haller (Jim Haller) as its new Executive Director, effective May 8, 2023. A passionate advocate for consumer bankruptcy rights, Mr. Haller brings a wealth of experience and leadership to the NCBRC as it continues to serve its mission of preserving and enhancing the rights of consumer bankruptcy debtors. Posted: April 29, 2023 Remarks as Prepared for Delivery. Speaker: Vanita Gupta, Associate Attorney General Posted: March 27, 2023 This year NACBA is pleased to announce that Natalie Jean-Baptiste is the recipient of the 2023 Henry J. Sommer Scholarship! Natalie will be recognized for this scholarship during NACBA’s 31st Annual Convention being held in our nation's capital, Washington, DC. Posted: March 24, 2023 Chief Justice John Roberts of the U.S. Supreme Court has appointed Jenny L. Doling to serve a three-year term on the Judicial Conference Advisory Committee on Bankruptcy Rules. Posted: February 27, 2023 The Justice Department today officially swore in Tara Twomey as the new Director of the United States Trustee Program (USTP). 2022On June 21, 2022 the U.S. House of Representatives passed S. 3823 Bankruptcy Threshold Adjustment and Technical Corrections Act. Posted: June 8, 2022 On June 7, 2022 the U.S. House of Representatives passed S. 3823 Bankruptcy Threshold Adjustment and Technical Corrections Act. Posted: April 28, 2022 This year NACBA is pleased to announce that Karina Rocha is the recipient of the 2022 Henry J. Sommer Scholarship.. Posted: April 12, 2022 S. 3823 "Bankruptcy Threshold Adjustment and Technical Corrections Act" Passes U.S. Senate, Advances to U.S. House Posted: March 17, 2022 Certain dollar amounts in the U.S. Bankruptcy Code will increase effective April 1, 2022, pursuant to 11 U.S.C. §104. On February 4, 2022, the Judicial Conference of the United States announced and detailed these changes in The Federal Register. Posted: February 16, 2022 On February 16, 2022, NACBA, on behalf of its members and their clients, submitted comments to the Judicial Conference of the United States Advisory Committee on Bankruptcy Rules concerning the proposed amendments to Federal Bankruptcy Rules and Official Forms. 2021Posted: August 28, 2021 Statement of the National Association of Bankruptcy Trustees, National Association of Consumer Bankruptcy Attorneys, National Association of Federal Equity Receivers Regarding the Perilous Condition of Afghanistan Judges Posted: August 3, 2021 The National Association of Consumer Bankruptcy Attorneys (NACBA) commends Senator Richard Durbin (D-IL) and Senator John Cornyn (R-TX) for their bipartisan sponsorship of legislation which will provide bankruptcy relief for struggling student loan borrowers across the country. Posted: July 27, 2021 Kansas Bankruptcy Court Rules Proceeds from Post-Petition Claims Are Not Included in the Best Interest Test of Section 1324(a) After a Trustee’s Motion to Amend Plan to Compel Turnover Posted: June 3, 2021 Court Examines Split of Authority Regarding Reconversion Of A Case From 7 to 13 Posted: June 1, 2021 The Debtors filed a voluntary petition for relief under Chapter 7 of the Bankruptcy Code and indicated in the petition... Posted: May 17, 2021 On May 14, 2021 NACBA and National Consumer Law Center (on behalf of its low-income clients) sent a joint letter ... Posted: March 30, 2021 On March 29, 2021, the National Association of Consumer Bankruptcy Attorneys (NACBA) sent a letter to Administrator Isabella Casillas Guzman... Posted: March 29, 2021 We are happy to report that on Saturday, March 27, 2021 President Biden SIGNED H.R. 1651 into law. The amended... Posted: March 29, 2021 On March 17, 2021 the National Association of Consumer Bankruptcy Attorneys (NACBA) submitted a letter to Director Clifford White at... Posted: March 26, 2021 Yesterday NACBA shared that the U.S. Senate passed an amended H.R. 1651 “COVID-19 Bankruptcy Relief Extension Act of 2021”. The... Posted: March 25, 2021 As NACBA reported, on March 17, 2021, the U.S. House of Representatives passed H.R. 1651 “COVID–19 Bankruptcy Relief Extension Act... Posted: March 18, 2021 In light of on-going developments with COVID-19 and after thoughtful discussions with our Board of Directors and several dedicated NACBA... Posted: March 18, 2021 On March 17, 2021, the U.S. House of Representatives passed H.R. 1651 “COVID–19 Bankruptcy Relief Extension Act of 2021”. Among many... Posted: March 17, 2021 The National Association of Consumer Bankruptcy Attorneys (NACBA) submitted a letter, March 17, 2021, to Director Clifford White at the... 2020Posted: December 9, 2020 The National Association of Consumer Bankruptcy Attorneys (NACBA) commends Senator Elizabeth Warren and House Judiciary Chair Jerrold Nadler for their... Posted: September 30, 2020 On Tuesday, September 29, 2020 the House Judiciary Committee led by Chairman Jerry Nadler (D-NY), held a markup hearing and... Posted: September 8, 2020 Published: Sept. 8, 2020 at 8:26 a.m. ET, MarketWatch By John C. Colwell U.S. Bankruptcy Code should be overhauled to... Posted: August 3, 2020 Due to the global COVID-19 (Coronavirus) pandemic, the National Association of Consumer Bankruptcy Attorneys (NACBA), has no choice but to... Posted: July 30, 2020 For Immediate Release The National Association of Consumer Bankruptcy Attorneys (NACBA) and National Consumer Law Center (NCLC) on Wednesday hosted a... Posted: May 20, 2020 As a majority continue to follow stay at home orders due to the COVID-19 crisis, NACBA’s Legislative Committee with support from NACBA’s Board of Directors have been working nonstop with House and Senate staff to ensure significant bankruptcy provisions were included in H.R. 6800, Health and Economic Recovery Omnibus Emergency Solutions Act, also known as the “HEROES Act”. Posted: May 7, 2020 The NACBA 2020 Board of Directors Election Results are as follows: Tara Twomey, Esq., of Carmel, CA (Seat #1), Gene Melchionne, Esq., of Waterbury, CT (Seat #2), and Pamela Stewart, Esq., of Houston, TX (Seat #8). Posted: April 15, 2020 WASHINGTON, D.C.- On April 13th, 69 community, civil rights, consumer, and student advocacy organizations, including NACBA, sent a letter to House and Senate leadership, urging them to include student debt cancellation in the next coronavirus package. Posted: April 14, 2020 The Debtor in this case was successfully represented by NACBA member Mr. David Wilkinson of Frego & Associates – The Bankruptcy Law Office, PLC in Dearborn Heights, Michigan. In this case the Debtor filed a chapter 7 bankruptcy without her spouse. Their combined income was above median and therefore the Debtor had to complete Chapter 7 Means Test Calculation on Form 122A-2. Posted: March 27, 2020 This week NACBA performed a survey of how different courts are addressing the coronavirus pandemic. Every district’s website was examined for published orders or policies. All orders regarding wet signatures are linked along with other orders regarding COVID-19 in an Excel spreadsheet. Posted: March 26, 2020 The National Association of Consumer Bankruptcy Attorneys (NACBA) has been working hard advocating behind the scenes (while maintaining a safe social distance) with House and Senate Judiciary Members and staff to get bankruptcy provisions passed in the current legislation known as the “CARES Act”. Posted: March 24, 20201 The unprecedented pandemic we are now experiencing will without doubt cause financial hardship to millions of Americans who had no hint that their otherwise stable economic situations would be disrupted so completely. Even with payment moratoria and temporary bans on foreclosures and evictions, their bills will eventually come due and in many cases, without income that is lost forever, those debts will be insurmountable. Absent permanent relief, families will face wage garnishments, evictions and foreclosures. Posted: March 18, 2020 NACBA is carefully monitoring the evolving coronavirus situation. Like many, we are hopeful for an effective solution in the near future. In the meantime, we are pleased to announce that NACBA’s 2020 Members-Only Workshop, December 1 – December 4, 2020 at the Grand Hyatt Kauai Resort & Spa in Koloa, Hawaii will be transformed to a convention / workshop hybrid atmosphere. Posted: March 18, 2020 What are the dangers in filing an emergency bankruptcy petition for a Debtor you never met and who didn’t sign the bankruptcy petition? (Bankr. N.D.TX.) Posted: March 17, 2020 Effective immediately, all in-person chapter 7, 12, and 13 section 341 meetings scheduled through April 10, 2020, are hereby continued until a later date to be determined. Posted: March 10, 2020 Please note, if you are already a member of NACBA, THANK YOU for your support of the profession. If you... Posted: February 24, 2020 Prior to the Debtor’s bankruptcy he had some serious real estate tax issues. He owned real property in Pendleton County, Kentucky (the “Rogers Property”) but failed to pay taxes for tax years 2003, 2004, 2006 and 2007. The County sold the tax certificates to Kentucky Tax Bill Servicing, Inc. (“KTBS”) which filed a state court lawsuit in 2010. The lawsuit requested a personal judgment against the debtor, foreclosure of the certificates and public sale of the property. The Debtor did not respond and the state court entered an “In Rem Judgment and Order of Sale” against the Rogers Property. The 2012 judgment was silent as to the Debtor’s in personal liability. Ultimately the Rogers Property was conveyed to KTBS. Posted: February 18, 2020 Prior to this case the Debtors had filed three chapter 13 cases in quick succession from late 2015 to early 2016 all of which were dismissed without a confirmed plan. The debtors filed this chapter 13 case in March of 2019 and were originally represented by counsel. Counsel was forced to file an emergency petition to stay a state court hearing. This was a skeleton petition without schedules, statement of financial affairs or the plan. Later, council move to withdraw as Debtors’ counsel which was granted. Posted: February 9, 2020 NACBA continues to advance, and we visualize the upcoming year to be one of uninterrupted fortune. Looking back, the 2019 calendar for NACBA was replete with success. 2020 and 20/20 indeed! Posted: January 24, 2020 Prior to filing for bankruptcy, the Debtor incurred a student loan (ultimately held by Navient) to attend the Reformed Theological Seminary. The seminary was not a Title IV accredited institution. The Debtor filed bankruptcy, listed this loan and received an order of discharge. Both Navient and Experian Information Solutions LLC. (“Experian”) received notice of the discharge order. Experian prepared the Debtor’s credit report and described the Navient Loan as “account charged off,” with an outstanding balance and a past due balance. Posted: January 9, 2020 Prior to filing bankruptcy, the Debtor borrowed money to pay for his undergraduate education. After graduating and serving in the United States Navy for five years, he borrowed additional funds to attend and complete law school. After graduating from law school his consolidated debt was $116,464.75. The total outstanding balance as of November 2019 was $221,385.49. 2019Posted: December 6, 2019 Does a creditor violate the automatic stay by threatening a debtor with criminal prosecution to collect a civil debt? (Bankr. W.D.VA.) In chapter 13, can an under-secured 910-car creditor tack on post-petition attorney’s fees? (Bankr. W.D.AR.) In a chapter 7 case, does the bankruptcy estate include proceeds from a post-petition settlement for events that occurred pre-petition? (Bankr. ID.) Can an appellate court summarily affirm a lower court when the appellant’s argument is seriously deficient and in utter disregard of the applicable procedural rules? (B.A.P. 1st. Cir.) Is the bankruptcy court required to dismiss a chapter 7 bankruptcy for failure to comply with the credit counseling requirements when dismissal is opposed by the Trustee holding assets? (Bankr. W.D.N.C.) Posted: November 30, 2019 Does a bankruptcy court have the discretion to deny an amendment of exemptions if the amendment is in bad faith or would prejudice creditors? (8th Cir.) What are the dangers in filing an emergency bankruptcy petition for a Debtor you never met and who didn’t sign the bankruptcy petition? (Bankr. N.D.TX.) Does the bankruptcy court have to sustain an objection to confirmation of a provision of the national uniform plan (Official Form 113), because the plan fails to include an additional non-standard provision specifically providing that the holder of the ‘910 claim’ retain the lien securing its claim until the earlier of payment of the underlying debt determined under nonbankruptcy law or discharge under section 1328? (6th B.A.P.) In a chapter 13 bankruptcy, can a debtor claim an expense on the means test for a monthly mortgage obligation for her elderly mother-in-law? (Bankr. E.D.VA.) In an above-median income chapter 13 bankruptcy, can the Trustee object to confirmation based on the necessity of expenses claimed solely on Schedule J? (Bankr. N.D.TX.) Posted: November 23, 2019 Does a chapter 7 debtor have standing to object to the trustee’s proposed sale of assets? (8th B.A.P.) Can a debtor exempt a rifle as “[n]ecessary apparel, bedding, foodstuffs, household furniture and appliances?” (Bankr. D.CT.). Is failure to disclose ownership of real estate grounds to deny a debtor’s motion to convert a chapter 7 to chapter 13? (Bankr. N.D.MS.) In a chapter 7 proceeding filed by one spouse only, what method should the Bankruptcy Court use to allocate tax refunds received from a joint tax return? (Bankr. N.D.IL.) Can a bankruptcy appeal be dismissed under the “fugitive disentitlement doctrine” for an appellant that has “skedaddled”? (1st Cir.). Posted: November 16, 2019 Does a calendaring error made by Debtor’s counsel constitute “excusable neglect” under Civ. P. 60(b)(1) and Fed. R. Bankr. P. 9024? (Bankr. E.D.MI.) Can Debtors defend against a trustee’s tuition claw back by asserting they received the economic benefit of a financially self-sufficient child? (1st Cir.) In a dispute whether a chapter 7 case should be dismissed for “substantial abuse” does the Debtor’s voluntary plans to retire soon constitute “special circumstances” under the means test? (Bankr. N.D.GA.) Can judicial estoppel be used to dismiss an undisclosed lawsuit even if all creditors in the bankruptcy have been paid? (10th Cir.) Are chapter 13 debtors required to file objections to unsecured claims that claim interest in Section 9 of Official Form 410 (Proof of Claim)? (Bankr. N.D.OH.) In a chapter 13 proceeding, should post-petition parking or moving violation tickets be treated as administrative expenses? (7th Cir.) Posted: November 8, 2019 Can a state agency argue that a debt is non-dischargeable under Section 523(a)(7) if it began criminal proceedings to collect the debt post-petition?(Bankr. N.D.AL.) Does a chapter 7 debtor have standing to object to a claim? (Bankr. E.D.NY.) Can debtor’s counsel be paid for work performed in a chapter 7 after the case is converted to a chapter 13 bankruptcy? (Bankr. E.D.MI.) Can the Court appoint counsel to assist a pro se debtor who is facing contempt sanctions including incarceration? (Bankr. D.ME.) Are a debtor’s alleged false verbal statements about his employment to a state unemployment agency enough to find the debt is non-dischargeable under 11 U.S.C. § 523(a)(2)(A)? (Bankr. D.CO.) Can a chapter 7 discharge be revoked under Sections 727(a)(6)(A) or 727(d)(3) (refusal to obey an order) if the debtor is unable to comply with the order? (Bankr. W.D.OK.) What is better evidence of real property value, a tax assessment or a broker price opinion? (Bankr. C.D.CA.) Posted: November 1, 2019 In a chapter 13, does a car creditor violate the automatic stay if the storage lot owner does not release a repossessed vehicle? (Bankr. E.D.MI.) Is a homestead refund credit received post-petition on real estate taxes paid pre-petition part of the bankruptcy estate? (Bankr. MN.) Does “excusable neglect” under FRCP 60 and Rule 9023 include out-and-out lawyer blunders—the type of action or inaction that leads to successful malpractice suits by the injured client? (Bankr. E.D.MI.) In a chapter 13, does a creditor have an affirmative duty to return a pre-petition repossessed vehicle? (3rd Cir.) Post-discharge, is a collection letter with a bankruptcy disclaimer a violation of the discharge injunction? (Bankr. W.D.MI.) Can a debtor use § 522(f) to avoid a judgment lien against property she acquired after the creditor recorded its judgments? (Bankr. S.D.FL.) Can a bankruptcy court sua sponte dismiss a chapter 7 bankruptcy as a bad faith filing? (Bankr. D.CT.) Posted: October 25, 2019 Does a Defendant asserting judicial estoppel have standing to object to a motion to reopen a bankruptcy (11 U.S.C. § 503) to disclose the omitted claim? (D. W.D.WA.) Can a debtor pay off a car title pawn loan over the duration of a chapter 13 bankruptcy? (Bankr. M.D.AL.) Can a physically separated married couple, filing separately, each claim a homestead exemption in two homes? (Bankr. KS.) Does a Section 362(k) action (stay violation) survive the dismissal of the underlying bankruptcy? (3rd Cir.) Can a bankruptcy court enforce a discharge order entered in a different jurisdiction? (5th Cir.) Can a debtor discharge a private education loan for attendance at an institution not eligible to participate under Title IV of the Higher Education Act? (5th Cir.) Posted: October 18, 2019 If a bankruptcy court denies a discharge under Section 727, does it have the authority to enter a money judgment against the debtor under a non-dischargeability proceeding under Section 523? (Bankr. E.D.MI.) Can a chapter 13 debtor cram down a residence which is part of a multi-use property? (10th B.A.P.) In a judicial estoppel situation, can the bankruptcy court infer an “intent to misuse the courts” just from a non-disclosure of an asset? (11th Cir.) In a 9011 sanctions proceeding, does a movant meet the “safe harbor” rule if it just serves the respondent with the motion for sanctions 21 days before filing it? (Bankr. C.D.CA.) Do bankruptcy courts have discretion to refuse to compel arbitration in proceedings seeking enforcement of a discharge injunction after the Supreme Court’s decision in Epic Systems Corp. v. Lewis, 138 S. Ct. 1612 (2018)? (5th Cir.) Posted: October 15, 2019 Prior to filing bankruptcy, the Debtor was sued in state court for fraudulent misrepresentation and for breaching a contract to restore a vintage automobile. A default judgment was entered against her. Ten years later she filed a chapter 13 bankruptcy. The creditor filed an adversary proceeding to determine the debt was non-dischargeable and a motion to dismiss or convert. The Debtor then filed an application to voluntarily dismiss her case under 11 U.S.C. § 1307(b). The bankruptcy court dismissed the case. On appeal the creditor’s chief argument was that Section 1307(b) does not give the debtor an absolute right to dismiss. The District Court disagreed. Posted: October 11, 2019 Can a debtor, post-deposition, make material, contradictory changes to his deposition transcript on the Errata Sheet? (Bankr. N.D.GA.) Can the bankruptcy court allow a late claim by a creditor omitted from a timely filed creditors list? (Bankr. MD.) Can a chapter 7 debtor invalidate a mortgage lien if the mortgage holder doesn’t maintain its files and delays 10 years before completing a non-judicial foreclosure? (Bankr. E.D.WA.) Can a chapter 13 debtor strip off an unsecured lien from real property that is titled as joint tenants with rights of survivorship, where the joint tenant is not a joint debtor in the bankruptcy case? (Bankr. E.D.VA.) Is an assignee of a consumer creditor contract liable for misdeeds of the originator of the contract under the “Holder Rule”? (Bankr. N.D.TX.) In a chapter 13 plan can a debtor cram down a 910-vehicle to value if the vehicle also secured other obligations to the credit union? (Bankr. S.D.FL.) Does the “weekend rule” in Bankruptcy Rule 9006(a)(1)(C) (deadline occurring on a weekend is extended to the next business day) apply to deadlines with a specific date? (Bankr. N.D.TX.) Can a Stern objection to the Bankruptcy Court’s authority be implicitly waived if not pled in a responsive pleading per Bankruptcy Rule 7012? (Bankr.N.D.IL.) |
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NACBA's 33rd Annual Convention | HOLLYWOOD
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