In re Rodriguez, No. 07-24687 (MBK), 2012 WL 589553 (Bankr. D.N.J. Feb. 22, 2012) (Kaplan)

On remand after Third Circuit held that escrow shortage was prepetition debt, Countrywide willfully violated automatic stay by attempting collection of prepetition escrow claim. Postpetition billings contained prepetition escrow and threats of late charges.

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