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BANKRUPTCY LAW

9/16: IN RE: Gregory Joseph MILLER;

Tammy Lynn Miller

In a bankruptcy action, where the bankruptcy court dismissed a creditor's adversary complaint alleging that its legal fees were nondischargeable because the debt was obtained by fraud, and sanctioned the creditor, the district court's ruling vacating the sanctions order is: 1) affirmed in part, where the district court correctly concluded that the sanctions order violated the procedural "safe harbor" requirements of Fed. R. Bankr. P. 9011; but 2) reversed in part and remanded with instruction to permit the bankruptcy court to consider alternative avenues to impose sanctions.


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