Chapter 13 debtor’s failure to provide evidence of a change in financial circumstances justifies the denial of a motion to modify seeking to reduce the dividend and related payments into the plan. (Cleary) In re DeRoo, 650 B.R. 561 (Bankr. N.D. Ill. May 2, 2023)
Nicole DeRoo filed a Chapter 13 petition in February of 2022. Above-median income and proposed plan would pay a 100% dividend over 57 months. It was confirmed. At the time of confirmation, the debtor had monthly disposable income . . .
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