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Illinois Southern District

Judges Split on Denial of Chapter 13 Discharge for Missing Direct Mortgage Payments

Illinois judges disagree on whether direct payments to a mortgagee are “under the plan” and must be made in full to obtain a chapter 13 discharge.

Rule 9(b) Fraud Pleading Standards Don’t Apply to an FDCPA Complaint

Willfulness is not required by the FDCPA when pleading an automatic stay violation.