Memorandum re Sanctions
ALAN JAROSLOVSKY, Bankruptcy Judge.
I. Introduction
Low- and middle-income debtors who are sued by credit card issuers over dischargeability do not face an even playing field. Such creditors are required to show actual fraud before they are entitled to judgment. However, a debtor who wishes to stand on his rights risks disaster if he or she loses the case. Credit card issuers usually take the position that, pursuant...
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