Rachel L. Steinlage serves as law clerk for Judge Pat. E. Morgenstern-Clarren (N.D. Ohio).1
When debtors file chapter 13 cases, they are often in default of payments on the mortgage note secured by their primary residence, or default post-petition. In that situation, debtors usually enter into an agreed order with their lender in an effort to resolve the default. In most of these agreed orders, the debtor acknowledges that a post-petition default under . . .
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