Section in 109(g)(2) of the Bankruptcy Code bars a debtor from filing a new case for 180 days if the Debtor voluntarily dismisses a case “following” a motion for relief. Not surprisingly, courts are split on how they interpret the word “following” as used in § 109(g)(2). After all, the word “following” is not limited to one definition, or even one part of speech for that matter – it can be used a preposition, a noun, a pronoun, an adjective, or a verb. There are several ways that courts have interpreted the term in connection with § 109 . . .
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