Critical Case Comment

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By Henry E. Hildebrand, III, Chapter 13 Trustee, Nashville, TN

In re Howard, 507 B.R. 394 (Bankr. N.D. Ga. March 14, 2014) (Sacca) - Where the grace period to redeem pawned property expired prior to the filing of the Chapter 13 petition, the property was not property of the estate and the debtor could not treat this claim as a secured claim.

Case Summary

Ms. Howard had pawned two automobiles with USA Title. She had signed a pawn contract for a 2006 Suzuki in exchange for $1,856.18 and signed a second pawn contract . . .

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