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Fourth Circuit Stands Alone in Limiting Chapter 13 Plan Modifications

Eleventh Circuit joins the majority of circuits by holding that unforeseen, changed circumstances are not required to modify a chapter 13 plan.
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Ninth Circuit BAP Allows a Complaint to Revoke Discharge After 180 Days

The Ninth Circuit BAP follows a Pennsylvania bankruptcy court decision with facts more similar than those in Ninth Circuit precedent.
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