Objection to Confirmation of Chapter 13 - Ineligible

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109(e) looks at eligible petition date claims. That claims wasn't liquid as of the petition date.
Law Office of Peter M. Lively * Personal Financial Law Center I
11268 Washington Boulevard, Suite 203, Culver City, California 90230-4647
Telephone: (310) 391-2400* Toll Free: (800) 307-3328 * Fax: (310) 391-2462
On Thursday, December 21, 2017, 1:58:54 PM PST, bcc4929@gmail.com [cdcbaa] wrote:
Mates:
I represent a general unsecured creditor with a USDC judgement for $210,000 based on a violation of 42 USC 1983.
My client's Judgment on the Verdict for Plaintiff in USDC provides: otion.
We will move to lift the automatic stay of the Debtor's bankruptcy to return to the USDC to formally liquidate my client's damages, costs, and fees.
I want to object to confirmation of the chapter 13 plan, by arguing that the full amount of my client's claim ($210k + includingmy client's damages, costs, and fees) will increase the debt ceiling of 109(e), and render the Chapter 13 debtor ineligible.
Does anyone have such an Objection to a plan, based on these facts?
BCC
Baruch C. Cohen, Esq.
Law Office of Baruch C. Cohen, APLC
4929 Wilshire Boulevard, Suite 940
Los Angeles, CA 90010
Office (323) 937-4501 | Cell (323) 353-9535
Facsimile: (323) 937-4503New Email:bcc@baruchcohenesq.com
www.BaruchCohenEsq.com

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