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'Chapter 20' Debtors Can Strip Junior Liens, 9th Circ. Says
A Ninth Circuit bankruptcy panel ruled Thursday that distressed homeowners who convert from Chapter 7 to Chapter 13 bankruptcy can strip wholly unsecured junior liens, joining a growing number of circuits that ruled the Bankruptcy Code permits "Chapter 20" debtors this lien avoidance. Boukatch et al. v. Midfirst Bank et al., case number 14-1483, before the U.S. Bankruptcy Appellate Panel of the Ninth Circuit.
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