MEMORANDUM
DALZELL, District Judge.
I. Introduction
Callye Bistrian appeals a decision of the United States Bankruptcy Court for the Eastern District of Pennsylvania to convert her Chapter 13 petition to a Chapter 7 liquidation. She presents three questions for our review. First, may a debtor orally request a voluntary dismissal of her Chapter 13 petition at a hearing on another party's motion, or must she instead file a written motion...
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