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From the Editor – Fee-only Plans
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By The Honorable William Houston Brown (Retired)
Below-median debtor unable to afford upfront fees could file fee-only plan. Discussing the issue in the context of good faith, the court found that the debtor was facing numerous garnishments from healthcare creditors, and the debtor could not afford to pay the typical upfront fee required by attorneys for filing Chapter 7. The Code does not require any minimum distribution to creditors in Chapter 13, and the Code does not prohibit attorney-fee-only plans. In re Dunson, ________B.R.________, 2016 WL 2604341 (Bankr . . .
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