OPINION
WOLIN, District Judge.
Before this Court is an appeal by creditor-appellant, The Money Store Investment Corporation ("MSIC") of an Opinion and Order of United States Bankruptcy Judge Rosemary Gambardella. In re Cummings, No. 96-22768 (Bankr.D.N.J. Dec. 13, 1996) (taped on December 13, 1996). The bankruptcy court held that the debtors, John J. and Debra M. Cummings (the "Debtors" or the
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