Lam Motions and chap 13 Eligibility

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Yahoo Bot
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Has anyone, besides Lou Esbin, briefed this issue? Could I get a copy of the brief? Judge Tighe is working on a memorandum in which she is going to rule that the unsecured portion of the secured debt is counted re eligibity. She gave me until the end of next week to file a brief talking her out of it. It seems to me to come straight from the code but she commented that "all these other cases [from other jurisidictions]" rule that the unsecured portion, especially created by a Lam motion, must be included as unsecured debt in the eligibilty analysis. I need these other cases and legislative history etc.

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