Progress Report 2012: Special Education Reforms

In 2010, the New York City Department of Education (“DOE”) implemented special education reforms, which included a multi-phase overhaul of the City’s special education programs. The DOE’s chief concerns appeared to be increasing graduation rates for special education students and the proportion of the special education population served in general education settings, as opposed to specialized, segregated special education environments. This was a major undertaking considering, according to DOE-provided statistics, that City schools serve an estimated 160,000 special education students, only about 31% of those students with identified special needs graduate from high school and only 4% of students in self-contained special education classrooms graduate from high school.

When these reforms began in 2010, the 260 schools selected to participate in Phase One were charged with implementing many sweeping changes, but because the reforms initiated funding on a per capita, rather than whole-classroom, basis, most schools realized no significant uptick in funding to implement the required changes.

This fall, the DOE implemented the reforms Citywide. However, several studies conducted during Phase One have yielded disappointing results.  Most educators involved in the process have acknowledged difficulty changing the culture of schools to the point where there are sufficient staff with the knowledge and desire to effect the reforms’ systematic changes.  Furthermore, contracts with service providers (such as psychologists and speech-language pathologists) are geared to the old system, when special needs students were segregated into a handful of schools; now that special needs students are attending their neighborhood schools, many find service providers too geographically remote to obtain effective, consistent services.  And, as Randi Levine, an attorney at Advocates for Children of the City of New York, expressed in testimony before the New York City Council in June, “ambitious reforms require significant planning, capacity building and community buy-in.  While the DOE has met with us on a regular basis and has implemented many of our ideas, we are distraught that the DOE has not answered some basic questions that we have been asking for more than a year.”  Specifically, says Levine, the DOE has not set forth a consistent, thoughtful plan for a presumably common scenario: when a student’s zoned school does not offer the specific type of classroom or services required by that student’s IEP.  According to another recent article, Advocates for Children has fielded more than 40 calls from parents of special needs kindergarteners whose zoned schools have been unable to provide these students with the classroom type they require.  Many of these situations have been remedied by the DOE; however, the 40 families that contacted Advocates for Children do not represent the full universe of children who are not well served under the reforms, only those whose parents have spoken out on their behalf.

In a recent article in the New York Daily News, educators and their union representatives expressed concern that students enrolled in Phase One programs were actually faring worse on standardized tests than students remaining in self-contained special education classes.  Even though a study conducted by the DOE did not show the same disparity, the DOE study did show that students in Phase One did not demonstrate any improvement over non-Phase One students.  This did not, however, stop the DOE from rolling out the reforms Citywide this past September, nor did it cause the DOE to substantially tweak the program.

It is clear that parents and advocates should not jump to conclusions in the face of this data.  Two years is simply not long enough to accurately assess the long-term potential of the DOE’s reforms.  However, it is troubling that the DOE has not been forthcoming with data supporting its assertions that special needs students are faring better under the reforms than in traditional, self-contained classrooms.

So what can be done?  Certainly, at a minimum, DOE needs to provide comprehensive training to classroom teachers, administrators and support staff charged with implementing these reforms.  The DOE also needs to enforce a policy of transparency relating to educational data concerning the efficacy of the reforms, and how this data is being used to improve educational outcomes.  However, it is of the utmost importance that New York City parents of special needs students remain engaged and informed so that they can become successful advocates for their children.  While the DOE is ironing out the wrinkles, it is imperative that children not be left behind, and there are resources available to parents, including legal services such as those provided by this firm, to ensure that the transition to the educational environment envisioned under these reforms is a smooth and productive one for all students.

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NOW AVAILABLE: OCA’s Online Voter Guide

With Election Day fast approaching, it’s easy to focus only on the headline-grabbing national races.  So many of us have, at one time or another, found ourselves in a voting booth staring at a list of candidates in the local races, having either never heard any of the names, or being unable to articulate each candidate’s platform or otherwise meaningfully distinguish between the candidates.  This is partially a function of time and partially a function of interest.  With so many issues and decisions on the national front, it becomes harder to justify devoting time and effort to local races that, by comparison, appear meaningless.

If there’s one type of race about which New Yorkers of all stripes and political persuasions should truly care, however, it’s the various races deciding the currently vacant elective judicial offices in New York State.  Having a President who shares your views on important issues is nice; having a judge who is capable, competent, fair, intelligent and thoughtful is crucial to our livelihoods, the efficient administration of justice and the establishment of just and responsible legal precedents.

Hopefully, none of you will be charged with a crime or involved in ongoing litigation in the near future.  Still, it doesn’t hurt to take a look at the judicial candidates prior to the election, so that those New Yorkers who hit the voting booths this November are voting with conscience and knowledge, rather than randomly.  To that end, the Office of Court Administration has compiled a Voter Guide for the judicial races, complete with third-party ratings of the candidates’ qualifications.

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Death and Taxes: the Uncertainty of Inevitability in 2013

In 2001 and 2003, then-President George W. Bush enacted legislation increasing federal estate and gift tax exemptions to unprecedented levels.  These tax breaks were originally scheduled to expire in 2010; however, President Barack Obama temporarily extended them through the end of this year.  As things currently stand, each taxpayer is allowed a $5,000,000 exemption for 2011 and a $5,120,000 exemption for 2012 (these are also the current exemptions for generation-skipping transfer and gift taxes).  Additionally, the maximum federal tax rate for estates greater than the exemption is 35%, and the concept of portability was introduced to estate planning: for decedents dying in 2011 and 2012, if the first spouse to die lacks sufficient funds in his estate to claim the entire exemption, then the unused portion of the exemption can be transferred to the surviving spouse.  The gift tax exemption is also portable between spouses; however, the generation-skipping transfer tax is not.

So, what does this mean for those of us who, knock on wood, won’t die before the new year?  President Obama extended these tax breaks once – he’ll do it again, right?

Not necessarily.  These questions are largely unresolved due to the upcoming presidential election, and it is unlikely we will have any action before then.  President Obama’s current proposal is to reduce the estate and generation-skipping transfer tax exemptions to $3,500,000 and the gift tax exemption to $1,000,000.  Under the President’s plan, the top estate, gift and generation-skipping transfer tax rates would be 45%.  However, the President would make the ability to port unused exemptions between spouses permanent.  Mitt Romney, on the other hand, favors repealing the federal estate, generation-skipping transfer and gift taxes entirely.  The direction these laws take will depend, in large part, on the outcome of the November election.  If President Obama and Congress fail to act prior to December 31, 2012, then the exemptions will revert to pre-2001 levels, meaning an exemption of only $1,000,000 and a maximum tax rate of 55% on any excess over the exemption.  Perhaps, if Romney wins the election, none of this will matter – but it’s certainly risky for Americans to wait out these uncertain times without considering the impact on their estates if they were to die during a lapse in the tax breaks.

These ever-changing tax implications are one of the biggest headaches for estate planning practitioners.  Considering that these particular taxes generate a relatively insignificant amount of revenue for the country, at times it hardly seems worth the effort to draft estate plans to accommodate every possible legislative whim.  However, at least for the time being, such careful planning is necessary to ensure that your family, friends and other beneficiaries reap the greatest possible benefit from your estate plan.

Because there is a great deal of uncertainty surrounding the future of the federal estate, generation-skipping transfer and gift tax exemptions, Americans with potential taxable estates greater than $1,000,000 should review their estate plans with their professionals and carefully consider whether changes should be made.  Some options worth consideration are making gifts (within the current gift tax exemption) to beneficiaries before the end of the year, whether outright or in trust; investing in real estate during the down market; prudently investing in marketable securities; and making estate documents as flexible as possible to accommodate fluctuating tax rates.

The good news: the yearly federal gift tax exemption should rise from $13,000 to $14,000 in 2013.  However, don’t expect much of a break with your paychecks: income and capital gains taxes are set to increase significantly, to go along with new Medicare taxes.  Also, the social security tax cuts we currently enjoy will expire at the end of the year.  Taxpayers in every bracket would be wise to consider these issues throughout the fall by reviewing their estate plans, making adjustments with their employers concerning withholding amounts, adjusting retirement and college savings plans, tweaking monthly budgets and carefully considering the impact of federal, state and local elections on their financial bottom lines.

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Gunderson v. Park West Montessori, Inc. in Practice: a New Horizon for New York City Parents

In an April 29, 2012 article, the New York Times explored a very timely issue facing New York City parents: what happens when a family commits to sending a child to private school, then changes its mind?

This issue has arisen in several contexts lately.  The New York Times piece explored the situation of a family on the Upper West Side that committed to sending their child to a Manhattan private school, paid the deposit, promptly notified the school well before the start of the school year that the family could no longer afford the tuition, but was told by the school that, despite the probability that another family would jump at the chance to take their child’s spot, the family was still on the hook for the nearly $30,000 annual tuition.  The Times piece also explored another common scenario, where the deadline to accept a spot at a private school precedes the date on which the public school Gifted & Talented programs send out their acceptances.  Parents who, understandably, would prefer that their children attend no-cost G&T programs over exorbitantly-priced private school programs, have found that the private schools are not so forgiving about these broken agreements.  Many schools have gone so far as to sue these parents for the full amount of tuition for the year, even if they have wait lists to fill any vacant spots.

These situations are frustrating, to be sure – both for parents, who desire flexibility, especially when being asked to pay upwards of $20,000 to $30,000, per child, for a year of elementary education, and for the schools, who themselves may be cash-strapped in this poor economy, need to rely on enrollment projections from the admissions process, and benefit from tuition forfeiture in these situations to stay afloat.

Something has had to give, however, and that something may be the case Gunderson v. Park West Montessori, Inc., a 2009 case from the New York State Supreme Court in New York County.  In Gunderson, a Manhattan family committed to send their child to Park West Montessori preschool (at an annual cost of $19,300).  The child’s mother, Sarah Brooks, was an adjunct lecturer at SUNY Stony Brook who obtained a tenure-track assistant professorship at James Madison University in Virginia.  The child’s father, Erik Gunderson, also obtained a position at the University of Virginia Medical Center, and they decided that moving to Virginia was the best option for their family.  The family informed Park West in April of 2009 that they were moving, and that their son would not be attending Park West in the fall.  This amounted to approximately 5 months’ notice to the school of the family’s intentions.  Park West, however, took the position that the family was still obligated to pay Park West the full tuition for the 2009-2010 academic year, even if the family decided to move.

Gunderson and Brooks sued Park West for, among other things, a return of tuition monies already paid, a declaratory judgment that no further monies were owed to Park West and a declaratory judgment that the clause in Park West’s enrollment agreement obligating Gunderson and Brooks to pay for the full year, even if they moved, was void and unenforceable.  On Gunderson and Brooks’ motion to compel Park West to provide documentation through discovery to support Park West’s claim of damages in the full amount of the annual tuition, New York Supreme Court Justice Walter B. Tolub held that the clause in the enrollment agreement obligating the parents to pay tuition, even if they move, would be enforceable only to the extent that Park West would actually incur damages due to the child not attending the school (also known as a liquidated damages clause).  The clause would not be enforceable, however, if the parents’ payment of the full tuition was a penalty for the child not attending the school, which was not tied to any actual damages sustained by the school.  Gunderson and Brooks, the court ruled, were entitled to discovery on the question of whether Park West was actually financially harmed by their child not attending the school.

What constitutes harm in this situation?  According to Tolub’s decision, liquidated damages must be proportionate to actual loss suffered.  If a school maintains a wait list for its classes, or if such school denied students admission to its classes due to the classes being full, it may suffer no damage at all if a child pulls out of the school months in advance of the school year, because another child is available to take the first child’s place.  Or, if a school does not maintain a wait list, and if another student is unavailable to take the departing child’s place, the school may be damaged up to the full amount of the annual tuition.  It is a fact-specific inquiry and, the judge ruled, the parents are entitled to documentation of the actual damages the school would suffer if their child does not attend.  It would be an unenforceable penalty for a school to promptly admit another child off the wait list to take the place of the departing student, and charge the departing student a full year’s tuition, effectively receiving double payment for the same spot at the school.

It appears from an order of the Supreme Court, Appellate Division, First Department, dated November 24, 2009, that Park West did initially appeal Tolub’s decision, then quietly reached a settlement with Gunderson and Brooks, which the court so-ordered on November 2, 2009.  Therefore, at least for the time being, Gunderson is the prevailing law in New York.

What this means, in practice, remains to be seen.  I recently represented a Brooklyn family who pulled their daughter out of a private school after the first day of school when, they believed, actions undertaken by the school breached their enrollment agreement.  I was able to successfully negotiate a return of tuition monies paid, and we entered into an agreement stipulating that the family owed no additional monies to the school.  In this case, the school did have a wait list, and it is understood that another child most likely was offered (and accepted) the spot previously occupied by my clients’ child.  What we may never know is whether this result, reached without resort to litigation, was due to Gunderson, or the school’s general distaste for bad publicity.  However, it seems likely that the tide is already turning in New York City private schools, with a new trend toward greater flexibility for parents who are unable (or unwilling) to honor private school enrollment contracts.

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Berman v. New York City: What Does it Mean for New York City Consumers?

New York City’s interest in regulating debt collectors is nothing new.  Back in 1984, the City passed Local Law 65, which required debt collection agencies to obtain licenses to perform collection activities within the five boroughs.  The City’s reasoning was set forth as follows:  “While the majority of those engaged in [the debt collection] business are honest and ethical in their dealings, there is a minority of unscrupulous collection agencies in operation that practice abusive tactics such as threatening delinquent debtors, or calling such people at outrageous times of the night.” N.Y. City Admin. Code § 20-488 (1984).

Much has changed since 1984.  In 1996, Congress passed the federal Fair Debt Collection Practices Act, which penalized abusive and harassing debt collection tactics, and many states, including New York, have since passed their own versions of this law. However, perhaps incentivized by the economic downturn and the general inability of the populace to timely repay debts, by many accounts, debt collectors have grown increasingly bold.  New York City, under Mayor Michael Bloomberg, determined that Local Law 65 was insufficient to stem the tide of aggressive and, at times, abusive collection activity.  According to the Urban Justice Center, in 2006 roughly 99% of collection lawsuits brought against consumers by third-party debt buyers relied upon invalid or falsified evidence. This was of great concern to the backers of Local Law 65, as third-party debt buyers, who are not concerned about maintaining long-term relationships with debtors, are more inclined to pursue litigation to collect debts, and frequently obtain default judgments against debtors who, it would appear, have not received proper notice of the claims against them and, accordingly, are denied any meaningful opportunity to appear and be heard by the courts.

In response to what the City viewed as a slippery slope of debt collection activities that were at best indifferent, and at worst actively predatory, in 2009 the City Council passed Local Law 15, which extended the reach of Local Law 65 to include third-party debt buyers and attorneys who collect debts under the umbrella of “debt collector.”  Promptly thereafter, certain New York law firms engaged in the collection of debts held by debt buyers, as well as a Delaware-based debt buyer, commenced an action in the United States District Court for the Eastern District of New York, captioned Berman v. NYC, 09-CV-3017 (ENV), challenging Local Law 15 and certain regulations passed in support thereof.  The plaintiffs alleged that Local Law 15 and its regulations were pre-empted by both New York State law and the United States Constitution’s Commerce, Contract and Due Process Clauses.

In Berman, decided September 29, 2012, Judge Eric N. Vitaliano sided with the plaintiffs in holding that Local Law 15 was pre-empted by both state and federal law.  In particular, Vitaliano held that New York State Judiciary Law §§ 53 and 90 already regulate the conduct of lawyers licensed to practice in New York, and that it remains firmly within the domain of the Supreme Court Appellate Divisions to sanction attorney conduct that does not conform with attorney ethical obligations.  Furthermore, noted Vitaliano, Local Law 15 violates the Contract Clause of the United States Constitution by interfering with contracts executed between debt holders and debt buyers, and is unconstitutionally vague. Vitaliano denied the plaintiffs’ motion for summary judgment for violation of the Commerce Clause of the United States Constitution.

I can almost hear you thinking – this is all a bunch of legalese; what does it really mean, in practice?  How will it affect me, as a New York City debtor tired of relentless collection activity by debt collectors?  Well, that remains to be seen.  Judge Vitaliano noted in the Berman decision that Local Law 15 was ambitious, but it was unclear whether Local Law 15 would have provided much, if any, benefit for consumers. Vitaliano did not doubt that abusive debt collection practices are rampant in New York City, but did doubt that Local Law 15 had the focus and the teeth to prevent these abuses from occurring. Furthermore, Vitaliano believed that the New York State courts and legislature are well equipped to address abusive debt collection tactics, and to regulate those who conduct debt collection practices within the State of New York. The fact remains that these matters are frequently litigated in state courts, and if recent studies are to be believed, virtually every default judgment obtained against New York City consumers is predicated on deficient evidence of the debt, service of process, or both. I can tell you first-hand, through my own experiences representing consumers in New York, that plaintiff debt collection agencies fail to properly serve defendants an extraordinarily high percentage of the time, and more consumers should take advantage of the opportunity to fight back against these tactics. Whether out of anxiety, shame or lack of funds, most consumers are not utilizing the full power of the courts described by Vitaliano, and the availability of this power was not affected by Vitaliano’s decision.

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UPDATE: Even Newer Hope for Student Loan Borrowers Contemplating Bankruptcy

On the heels of this week’s discussion of the strategic potential of bankruptcy, even if a significant portion of debt is educational, comes a decision in the case In re Jeffrey Howell and Rebecca Howell, 11-12685, from the Bankruptcy Court in the Western District of New York.  Howell recognizes a peculiar difficulty for holders of student loans that I did not touch upon in my earlier post, namely, the difficulty debtors have in filing petitions under Chapter 7, rather than Chapter 13, when a significant portion of their debt is educational.  This is because a debtor with an income higher than the median income for his state, who nevertheless spends an inordinate percentage of his monthly income on the repayment of his student loans, has difficulty qualifying for a Chapter 7 bankruptcy, and is often forced to consider Chapter 13.

Chapter 13 is not without its advantages, which are beyond the scope of this discussion.  The disadvantage, for many debtors, is that Chapter 13 does not wipe the slate clean.  Debts are not completely discharged, but a percentage of debts are paid off over time, based on the debtor’s monthly disposable income.  Because, as previously discussed, student loans are generally not dischargeable in bankruptcy, whether in Chapter 7 or Chapter 13, a debtor who is forced to pursue a Chapter 13 plan will receive a stay of efforts by creditors to collect upon student loans during the Chapter 13 repayment period, but those loans will continue to accrue interest while the debtor is forgoing monthly student loan payments in favor of making payments on other debts under the Chapter 13 plan, often for a number of years.  The result, all too often, is that the debtor obtains some measure of relief for some of their debts, but ends up even further in debt on the educational loans, for which the debtor can obtain no meaningful relief through the bankruptcy system.

Offering a small ray of hope is Howell, courtesy of the Western District of New York’s Chief Bankruptcy Judge Carl Bucki.  Debtors whose monthly income is above the median, including those debtors who may have relatively high-paying employment offset by high monthly student loan payments, can defeat the presumption that a Chapter 7 bankruptcy filing is abusive by demonstrating that their student loan payments are “special circumstances” siphoning off their monthly disposable income.

Chief Judge Bucki’s ruling does not accord with other rulings across the country, such as those in Pennsylvania, Ohio, Arizona, Kansas and New Hampshire, but follows an emerging trend started by bankruptcy courts in Alabama, Illinois, Indiana, Delaware, Oklahoma and Georgia.  The Howell ruling also is not binding upon other bankruptcy courts in New York.  However, until a contrary binding authority appears, there is reason to believe that Howell will benefit debtors with significant student loans who would otherwise not be eligible for Chapter 7 relief.  It certainly must factor into the strategy of bankruptcy lawyers counseling debtors whose income has not yet caught up to their educational debt.

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How Not to Lose Your Discharge Before it’s Even Granted

The decision to file for Chapter 7 bankruptcy protection has become so momentous, so fraught with what-ifs and what-thens, that the general consensus is that it’s this act of filing that is the hard part.  The papers are filed, the automatic stay is imposed on creditors, the judge and trustee are assigned, the Section 341(a) meeting of creditors is scheduled, and the debtor breathes a sigh of relief.  What could possibly go wrong?

The actual discharge of a debtor from his debts in a Chapter 7 bankruptcy proceeding does not occur until, best case scenario, 60 days after the 341 meeting, which is a meeting at which the bankruptcy trustee and a debtor’s creditors can question the debtor, under oath, concerning the debtor’s assets and liabilities.  In clear-cut cases, where a debtor has a relatively small amount of consumer debt and no assets, the trustee should close the debtor’s 341 meeting and promptly file a Report of No Distribution with the bankruptcy court.  Then, at the expiration of the roughly 60-day period following the meeting, the debtor will receive a discharge and move ahead with the promised “fresh start.”

Often, however, the process hits a few road bumps along the way.  The United States Trustee requires each case trustee to examine certain financial records, including bank statements, credit card statements, tax returns, mortgage statements, insurance policies and other documents evidencing assets and/or liabilities, for debtors whose unsecured debt exceeds $100,000.  The trustee may seek these documents promptly, well before the 341 meeting, or only after meeting with the debtor.  While the trustee is investigating the debtor’s finances, he will generally hold the debtor’s 341 meeting open and ask the debtor to stipulate that the time for the trustee to object to the debtor’s discharge will be extended for a certain amount of time.  During that time, the court will not enter the debtor’s discharge.

This investigation has been a pitfall for more than a few debtors.  Trustees often request a standard list of documents from debtors, to be supplemented by additional documents tailored to each debtor’s situation.  For instance, if a debtor’s petition and schedules show an interest in a partnership, a trustee might ask for the partnership agreement.  If a debtor’s petition and schedules show that a debtor has income disproportionate to his assets, a trustee might seek documentation of his income.  All too often, debtors are not forthcoming with these documents.  Sometimes they are actively hiding assets, and don’t want to turn over evidence of their deception.  More often than not, they are simply poor record-keepers, which is part of why they’re in such dire financial straits to begin with.  Other times they simply do not have the time or energy to deal with the trustee’s requests, and stall hoping that the trustee won’t bother pursuing these documents.

This is ill advised, as all three of these scenarios can, and very often do, result in the denial of a debtor’s discharge.  Providing these and other documents to the trustee is an absolute requirement, and it is a valid basis for the trustee to commence an adversary proceeding objecting to a debtor’s discharge.  The same is true for the debtor actively hiding assets – if the trustee can show that the debtor lied under oath (whether in the petition or schedules, at the 341 meeting, in a hearing before the court or in a deposition or other discovery papers), the debtor will surely be denied his discharge.  Simply stating to the trustee that you don’t have the documents anymore, you threw them out, is not a defense to denial of discharge.  Debtors have an affirmative duty to keep and maintain all financial records, or obtain them from any accountant, bank, institution, school, agency or person who might have access to them.

Here’s where things can get very messy for the dishonest or lazy debtor.  If the judge decides to deny a debtor his discharge, none of the debtor’s debts will be discharged as part of that bankruptcy proceeding.  Furthermore, any debts the debtor attempted to discharge in that proceeding will never, ever be dischargeable, even in a future bankruptcy proceeding.  And, if the debtor has assets, they might still be liquidated to pay the debtor’s creditors, including the trustee and his attorneys, who expended a lot of money seeking documents from the debtor and litigating the objection to discharge action.  Sometimes it doesn’t even end there – for very egregious cases, the debtor may actually be prosecuted for bankruptcy crimes.

The moral of this story is that it ain’t over until the discharge is entered.  Simply filing a bankruptcy petition does not absolve you of your obligations, and in fact creates new ones, to the trustee and the court.  The petition and schedules are statements under oath.  Lying (or not being thorough) on these documents is perjury, and sometimes even fraud.

Attempting to hide assets from a trustee is not a good idea.  True, trustees have mountains of cases to review every month, but they each have systems in place to weed out potential fraud and asset cases.  One trustee in the Southern District of New York recently reviewed a case where the debtor disclosed that he was an “employee” of a company, but did not disclose that the company was actually registered to his home address.  His petition and schedules did not reflect any ownership interest in the company, but the trustee had to investigate.  As it turns out, the company is not profitable and it is not a valuable asset of the debtor’s estate.  However, because the debtor dragged his feet getting documentation concerning the company to his trustee, the trustee was forced to bring an objection to discharge action against the debtor.  In the end, the debtor produced sufficient documentation and was able to obtain his discharge, but not before his attorney and trustee and the court itself jumped through hoops of fire.  The judge had to set down a date certain for the debtor to comply with the trustee’s requests or else the judge would “seriously consider” a motion for a default judgment denying the debtor’s discharge – generally not something this judge would be willing to do.  That’s how close this debtor came to losing his discharge – and all over the (possibly inadvertent) omission of a worthless ownership interest in the bankruptcy petition and schedules.

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