The Chapter 13 Debtor’s Last Hurdle: The Section 1328 Certificate
Chapter 13 New York bankruptcy involves plenty of paperwork, to say nothing of patience on the part of the debtor. One particular hurdle a debtor must overcome is completing the “section 1328” certificate—named for its place in the Bankruptcy Code—and submitting it on time. The discharge order depends on the debtor doing so. So what …
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