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IN RE SMITH

Case No. 18-23830(JNP).

631 B.R. 374 (2021)

IN RE: Catherine E. SMITH, Debtor.

United States Bankruptcy Court, D. New Jersey.

Signed June 24, 2021.

Attorney(s) appearing for the Case

Isabel C. Balboa, Chapter 13 Standing Trustee, Cherry Hill, NJ, Trustee, Pro Se.

S. Daniel Hutchison, Law Office of S. Daniel Hutchison, Woodbury, NJ, for Debtor.

MEMORANDUM DECISION

The primary issue in this matter is whether a debtor can include post-petition mortgage arrears in a Chapter 13 modified plan. PHH Mortgage Corporation ("PHH"), as the servicer,1 filed a certification of default seeking...

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