Campbell v. Countrywide Home Loans, Inc., 545 F.3d 348 (5th Cir. 2008)
Escrow shortages which accrue prior to the filing of a Chapter 13 petition are part of the pre-petition “cure” claim and their recovery should not be effected by increasing the escrow portion of the ongoing “conduit” payments post-petition.
Summary of the Case
The debtors filed a Chapter 13 petition in April of 2006 seeking to cure a default on their mortgage they . . .
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