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Default Judgments Are (Sometimes) Nondischargeable Under Issue Preclusion

If the parties litigate but the defendant eventually defaults, the default judgment can result in nondischargeability via issue preclusion, Eleventh Circuit holds.
Court: 

Fifth Circuit Makes Student Loans Even More Difficult to Discharge

Fifth Circuit now says that student loans must ‘impose intolerable difficulties’ to be dischargeable.
Court: 

How to Draft a Judgment to Be Nondischargeable in Bankruptcy

To be nondischargeable, a stipulated judgment must lay out facts showing the debt was incurred by false representation or actual fraud.

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